1< DAY 3 Thursday, 13th January 2000 2MR DAVID IRVING, Recalled. 3MR JUSTICE GRAY: Yes, Mr Irving? 4MR IRVING: May it please the court, with your Lordship's 5permission, I have brought the bundle of the documents 6that we were referring to last night. Unless your 7Lordship would see any reason against, I propose rapidly 8stepping through these documents, pausing at the ones 9which are significant as far as we can determine so far 10from the direction and thrust of the cross-examination. 11MR JUSTICE GRAY: Yes. You are in the middle of your 12cross-examination. So, in the ordinary way, we will wait 13and see when the documents became relevant to Mr Rampton's 14questions. 15MR IRVING: They have been in discovery throughout, my Lord. 16MR JUSTICE GRAY: I follow that. But I suspect most of them 17are going to become relevant to the answers you are going 18to be giving to some of the questions Mr Rampton 19is asking. 20MR IRVING: I do apprehend it will be useful to the court, I 21appreciate that it is your Lordship's court, but I believe 22it will be useful. 23MR JUSTICE GRAY: You may well be right. I cannot really tell, 24I have only glanced at it. Shall I ask Mr Rampton -- 25because he is cross-examining, so, on the face of it, he 26has the right to continue to cross-examine.

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1MR RAMPTON: I have no objection. In a sense, it is either 2evidence-in-chief in anticipation of cross-examination, or 3it is what one might call "premature re-examination". 4MR JUSTICE GRAY: Yes. 5MR RAMPTON: One way or the other it is going to make no 6difference. 7MR JUSTICE GRAY: If you are happy I will not stand in the way. 8 Before that happens I wonder if I could mention 9one or two administrative points? The first is, I think 10we are all agreed through nobody's fault, this is not a 11very suitable court and I am very concerned that there are 12members of the public who, I think, are not able to get in 13and listen and want to. Having made enquiries, as I said 14I would, I think there are two possible courts to which we 15could move which were not available or were not thought to 16be available when we started. One is court 73, which 17I have looked at and looks to me to be much better than 18this in almost every respect. There is, apparently, 19another one, which is in Chichester Rents in Chancery 20Lane, which is even bigger. I think I would have some 21slight personal preference for 73, but what I wanted to 22ask you is that I think we should move anyway, because 23this is not satisfactory and it seems to me, unless you 24are going to tell me there are insuperable problems, 25tomorrow is the day to do the move. Are you in agreement 26that that is the right thing to do?

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1MR IRVING: I would have suggested doing it over the weekend 2although I have no logistical problems myself -- 3MR JUSTICE GRAY: Well, I think they have a lot of problems 4ahead of them, but I think it is better to do it now than 5to struggle on and regret it every day from hereon. 6MR RAMPTON: That would suit us awfully well, if we could make 7a fresh start in what I call a "proper big court" on 8Monday morning. 9MR IRVING: Not a fresh start. 10MR JUSTICE GRAY: We will decide -- not a fresh start. 11MR RAMPTON: No, thank you. 12MR JUSTICE GRAY: We will decide during the course of today 13which it is going to be and, obviously, let you know. We 14will take it that on Monday we will be in a different 15court. 16MR RAMPTON: May I ask where exactly 73 is? 17MR JUSTICE GRAY: It is where all those new Court of Appeals 18are. 19MR RAMPTON: In the East Building. 20MR JUSTICE GRAY: Yes. 21MR RAMPTON: In the end I would have to say, my Lord, it is a 22matter for you. 23MR JUSTICE GRAY: I think it is, if you have strong feelings. 24MR RAMPTON: No, I do not know Chancery Lane much at all 25anyway. 26MR JUSTICE GRAY: That is point one.

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1 The next relates to the TA Law Transcripts which 2are being done. Really, I think I am saying this on 3behalf of the lady who is doing the transcribing. She is 4having the most appalling task. She is here all day, and 5she is by herself, as it were. It would help her if we 6could slightly slow down. Mr Irving, you speak fairly 7rapidly anyway. That is not a criticism at all. 8MR IRVING: I thought I was speaking slowly. 9MR JUSTICE GRAY: If you can bear in mind there is somebody 10trying to take down what you say, if we can try to 11remember to spell out the German names when they crop up 12for the first time. That is going to make everybody's 13life much easier. 14 There is one other point on the transcripts. 15The Day 2 transcript starts at page 104. My own feeling 16(and I do not know whether you share it, Mr Rampton) is 17that it would be better if every day started at 1, so you 18have Day 2, page 1, rather than page 104. I am told that 19is physically possible. So that is what I think we will 20have in the future. 21 That is all that I wanted to raise except that, 22Mr Irving, I have seen (and I do not know whether 23Mr Rampton has) your letter about the letter to me about 24the article in the Stuttgart press. Do you know about 25it? 26MR RAMPTON: No.

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1MR IRVING: I was going to ask, my Lord, I might, having given 2the Defendants time to consider it, if I might address the 3court briefly on the matter after the lunch adjournment? 4MR JUSTICE GRAY: If you would like to do that, that is fine. 5Mr Rampton? 6MR RAMPTON: I have no comment until I have seen it. 7MR JUSTICE GRAY: I do not suppose you will, even when you 8have. 9MR RAMPTON: I see. My Lord, the only thing I would mention 10about the transcript, I do not know what the cure is. Is 11that, normally speaking, of course, one can deduce what it 12was, but here and there -- this is not a criticism of the 13transcriber, far from it -- one sees in square brackets 14the word "German" which represents something that has been 15said in German. That is going to repeat itself 16indefinitely in that case. I do not know what cure is. 17Whether the word should be spelt out each time. It is a 18terribly laborious way of dealing it, or whether we supply 19at some stage when it is important a list of what we 20suppose was the word used. As I say, most of the time one 21can deduce it. 22MR JUSTICE GRAY: Is it actually going to be all that much of a 23burden to spell it out or, at any rate, spell out the key 24words in the document? I am thinking yesterday 25"liquidierung". One can spell that out. 26MR RAMPTON: There is going to be more of that today.

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1MR JUSTICE GRAY: I follow. 2MR RAMPTON: Perhaps spell it out? 3MR JUSTICE GRAY: I am inclined to think so. I think that is 4the best way. It is going to slow things down. Would you 5prefer it, both of you? 6MR RAMPTON: Yes. 7MR JUSTICE GRAY: It is going to slow things down, but it needs 8to be done that way. So, Mr Irving, would you like to 9take me through the... 10MR IRVING: Page 1, my Lord, this is a letter -- the sole 11purpose of this letter is that it indicates the date when 12I really made use of the Himmler telephone notes, being 131974; some 25 years ago, 26 years ago. 14MR JUSTICE GRAY: Can I just ask you this? You there 15transcribe judentransport, J-U-D-E-N-T-R-A-N-S-P-O-R-T, in 16the singular, and that is in 1974. 17MR IRVING: We have check the original in the German. You are 18absolutely right, my Lord. You are absolutely right. 19MR JUSTICE GRAY: Right. 20MR IRVING: In a very vague, and, of course, I am still 21considering myself to be under oath as I make these 22remarks, in a very vague way my recollection is that time 23I regarded the word "transport" as not just meaning like a 24transport train or one consignment, or a transport ship in 25the way that you would talk about a convoy of 26 26transports but also in the sense that transportation.

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1I consider that the words judenstransport meant 2"transportation of Jews". 3MR JUSTICE GRAY: Yes, I note that you make that point. 4MR IRVING: This is an alternative inference but now I am quite 5happy to accept that this particular discussion from 6external evidence only referred to one particular 7transport of Jews, and I am indebted to your Lordship for 8having reminded, or took me back into the mind set of 26 9years ago. 10MR JUSTICE GRAY: Yes. 11MR IRVING: As you know, my presumption is, I will just read 12the middle paragraph that Hitler had become an active 13knowledge bearer or accomplice in the destruction of the 14Jews only in 1943. This is of course a translation of the 15following page, my Lord. From the attached page, which is 16a facsimile, which we will see in a minute, it is evident 17that Himmler, arriving at midday on November 30th, 1941, 18in the Wolf's Lair, which I explain was Hitler's 19headquarters in East Prussia, after a brief conversation 20with Hitler immediately had to telephone Heydrich in 21Prague, and then comes the phrase, "judentransportest aust 22Berlin keine liquidierung", which I believe the shorthand 23writer already had from us. 24 If you take this in conjunction with various 25other entries, e.g. that of 17th November 1941, in which 26Heydrich informs the Reich Fuhrer, that is Himmler, on

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1conditions in the general Uberman, Poland. 2MR JUSTICE GRAY: That is SS Reich Fuhrer. 3MR IRVING: Well, Reich Fuhrer SS would be the full title. 4There was only one Reich Fuhrer in German -- conditions in 5the general government Poland-geting rid of the Jews, 6Beseitigung, this can only indicate that Himmler has been 7rapped across the knuckles by Hitler. This conversation 8note has until now evidently slipped through the fingers 9of the historical research community, as you might call 10it. 11 Then the other two lines at the bottom are not 12without interest in the chain of documents I refer to, my 13Lord. Himmler had to issue a similar "holt" order in 14April 1942 on account of the liquidation of the gypsies, 15again after a brief visit to Hitler. "I thought this 16might be of interest to you." You will see that document 17too, my Lord, in this bundle. Because it is false to try 18and draw inferences from one document without looking at 19other documents in the series. I appreciate in court it 20is difficult to do this. 21 My Lord, the next document I am going to draw 22your Lordship's attention to is 03 at the foot of the 23page. This is another document that was in discovery. 24MR JUSTICE GRAY: I have read that. That is you asking 25Professor Hinsley whether he has any more information. 26MR IRVING: Yes, my Lord, except that at that time it does

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1indicate at that time he did not have the German 2originals. 3MR RAMPTON: I am sorry, Mr Irving. I beg your pardon. May 4I intervene to ask your Lordship to insert it in that 5bundle? It comes from Mr Irving's discovery. There is no 6mystery about it. Professor Hinsley's reply. 7MR JUSTICE GRAY: It was not there. 8MR RAMPTON: Yes, we have it now. 9MR IRVING: I could not find it last night, my Lord. In is 10Professor Hinsley indicates that he has obviously not yet 11seen himself the German originals of the British 12intercepts. 13MR JUSTICE GRAY: Yes. 14MR IRVING: It is quite interesting. 15MR JUSTICE GRAY: The postscript is perhaps of some 16significance. 17MR IRVING: It is interesting the British Official Historian 18and British Secret Service had either not been allowed to 19see or had not found in general chaos the documentation, 20these are the originals, which are now in the Public 21Record Office. But the German originals are very, very 22informative in their scope, breadth and depth. 23 That, my Lord, is 04. This is the first of the 24notes of the telephone conversations from Himmler's 25telephone log to the Chief of the SS, and the one on which 26I rely is the one timed 12.15. It is the fourth

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1conversation. I am afraid I have not attached a 2translation of it, but I will do a translation on reply on 3the one or two lines that matter. It is a 15 minute 4conversation with Heydrich who on that day was in Berlin. 5We do not know who initiated the conversation, my Lord, 6but Heydrich phoned Himmler or Himmler phoned Heydrich. 7We never see them. We have to infer. Conference with 8Rosenberg, conditions in the government general, getting 9rid of the Jews, beseitigung of the Jews, and then the 10third line -- the fourth line rather, juristen 11nuralseerater, roughly lawyers just as advisers. 12 Nothing else on that page to which I will 13refer. Merely it shows there were conversations going on 14between these two gentlemen on liquidation or getting rid 15of the Jews. 16MR JUSTICE GRAY: What is the significance for my purpose of 17that? 18MR IRVING: It is the context in which the principal document 19is embedded, my Lord. The inference that has been drawn 20against me is that I have one cardinal document and 21I would go around the world waving this document and 22saying "here it the proof". It is, in fact, showing that 23they were constantly talking about getting rid of the 24Jews, using -- 25MR JUSTICE GRAY: There is no issue, is there, that that was 26something that both Himmler and Heydrich were intent upon

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1doing. 2MR RAMPTON: Yes. The word " beseitigung" is interesting. You 3can look at it either this way or that way, literally as 4getting rid of, which can be sweeping under the carpet or 5liquidation. I am quite happy to accept that here they 6were talking about liquidation, these two gentlemen. It 7now becomes more interesting, my Lord, on page 5. 8MR JUSTICE GRAY: Can you just let me highlight? 9MR IRVING: We come to the intercepts and Mr Rampton does not 10wish me at this point to bring in this material. I am 11quite happy to turn the page, but I think it is useful to 12bring it in all in chronological sequence. 13MR JUSTICE GRAY: When you "intercept" -- 14MR IRVING: This is the Bletchley Park intercept of the -- 15MR JUSTICE GRAY: Messages to Berlin. 16MR IRVING: Messages between Berlin and the Eastern Front for 17police commanders, and also a whole number of other SS 18units, but these are the ones I rely on. 19 No. 35 is a message addressed from Berlin on 20November 17th, that same day as the previous conversation, 21to the commander of security police, Dr Lange, L-A-N-G-E, 22in Riga, concerning, and I use the next word in original 23German -- these are my translations, concerning the 24evakierung of the Jews. "Evakierung", my Lord, is one of 25those words we will probably tussle over. The literal 26translation is "evacuation", but I am perfectly ready to

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1accept for the purposes of this action that "evakierung" 2is occasionally used by the SS as a euphemism for a more 3ugly means of disposing. 4 But in this particular case what is significant 5is that the man in Berlin is telling the recipient in 6Riga, on November 17th, in other words, that same day, at 76.25 p.m., transport train No. DO 26 has left Berlin for 8Kovno or Kornas, with 940 more Jews on board. That was 9usually the rough size of each train load of Jews, about 101,000 Jews. Transport escorted by two Gestapo and 15 11police officers. Transport commander is Criminal 12Overassessor Exner, the man's name, who was two copies of 13the transport list with him. Transport provided with 14following provisions, and this is interesting part, my 15Lord, 3,000 kilogrammes of bread, three tonnes of bread 16for a two or three day journey. 27 kilogrammes of flour, 17nearly three tonnes of flour; 200 kilogrammes of peas; 200 18kilogrammes of nutriments; 300 kilogrammes of corn flakes; 1918 bottles of soup spices. They continue in the next 20message; 52 kilogrammes soup powders, 10 packets of 21something or other, we do not know; 50 kilogrammes of 22salt; 47,200 Reich Marks in crates. Signed Gestapo 23Headquarters, Berlin. Quite an interesting document, my 24Lord. It is the first kind of thing we come across in my 25view to show that these trains were actually 26well-provisioned. It is a bit of a dent, a tiny dent in

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1the image that we have, the perception, as Mr Rampton 2calls it, of the Holocaust today. 3 The next one, page 6, is a message intercepted 4on 20th November. It is unimportant for our purposes on 5what day it was decoded. It was decoded 10 days. It 6takes 10 days to decode it. The actual message is dated 7three days later, 20th November 1941, again, dressed do 8commander of order police and the SS in Riga, concerning 9evacuation of Jews. The same kind of thing, transport 10train No. DO56. Has left Bremen, destination Minsk with 11971 Jews on 18th November. Escort command regular police 12Bremen, transport commander Police Meister Bockhorn, 13B-O-C-K-H-O-R-N, is in possession of two lists of names 14and 48,700 Reich Marks in cashiers' credits. Jews are 15well-provisioned with food and appliances. 16 My Lord, on the next page you will see the 17actual intercept, page 7 is what the actual intercept 18looked like. They are headed "Most Secret". It is the 19second paragraph, my Lord. 20MR JUSTICE GRAY: "Most secret" is put on at Bletchley, is it 21not? 22MR IRVING: Indeed, of course. There is no indication on the 23intercepts themselves, as intercepted here, what security 24classification they have. But I want to draw attention 25only to the word "gerat" in the fifth or sixth line of the 26intercept, which means appliances. Any German speakers in

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1the room I am sure would agree the word "gerat" is the 2tools of the trade, roughly, they are being sent to the 3East with food, with provisions, and with the tools of 4their trade. 5MR JUSTICE GRAY: You have translated that as what? 6MR IRVING: Appliances. It is a rough cover all, tools of the 7trade would be a little bit too specific, I am sure 8Mr Rampton will probably eventually object. But the sense 9of gerat, if a cameraman comes into this room he would 10bring his gerat with him, his appliances with him. 11 The next one is No. 15, I rely on this because 12it shows in the first line, I am sorry I am still on page 136, my Lord, the second message on page 6 SS Obergruppen 14Fuhrer Jeckelm, transferred from Kiev to Riga. So that 15was the day this criminal was transferred to Riga, round 16about November 20th, and in fact it is a pretty low level 17message. They are worried about what happened to motor 18cars and things like that if I remember correctly. 19 If we can now turn straight over to page 9, my 20Lord, I took the trouble during the night to dig out of my 21files, the war diary of Hitler's headquarters, which 22I have. These are all my documents. All my documents 23when I obtained them for the book, I had bound in these 24volumes because I anticipated perhaps Mr Rampton would 25say, well, we have no proof that Hitler was in his 26headquarters, that he was at home on the day of crucial

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1message November 30th. 2MR RAMPTON: No, he would not say that, my Lord, because 3Himmler recalls that he had lunch with Hitler on that day. 4MR IRVING: Well, I am just dotting the Is and crossing the Ts. 5MR JUSTICE GRAY: The point is not made, so we need not trouble 6with that. 7MR IRVING: It also talks about the arrival of the Fuhrer's 8train that very morning. On the following day is the 9photocopy from the page of war diary at Hitler's 10headquarters. We then come to the crucial document we 11were talking about yesterday evening, which I ... 12MR JUSTICE GRAY: I still have your copy of that. 13MR IRVING: I put it in the bundles for sake of completeness. 14It is referred to in the third conversation. I draw 15attention only to the first lines, which says: "Telephone 16conversation on November 30th 1941". The next line "Wolf 17stanche" means Wolf's Lair. The next line "ausdemzung" it 18means from the train. Himmler is still in the train going 19to Hitler's headquarters. 20 Three lines down, ausdembunker, from the bunker, 21he is at the bunker now, in the Wolf's Lair, 13.30 he 22telephones Heydrich, as we know only the third and fourth 23line of the notes are important, "Jew transport from 24Berlin, no liquidation". 25MR JUSTICE GRAY: Yes. 26MR IRVING: If I may proceed now to page 13, my Lord. This is

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1the one that I am alleged mysteriously to have misread and 2the implication being I deliberately misread it or 3deliberately changed word the Gerhartens Fuhrer (?) into 4"juden", which would be quite a feat. 5 My Lord on the page 13 the question of the line, 6the contentious line is third from the bottom, haben 7zubleiben. 8MR JUSTICE GRAY: Have to remain. 9MR IRVING: You will notice, my Lord, the word "haben" has 10obviously been retyped, a bit of squeeze getting it in. 11It was retyped by my when I realized my error in 12transcription. That typewriter was disposed of some or 13ten or 15 years ago. That is how early I realized my 14error. I do not know if it is significant one way or the 15other, it may count against me. I do not know. 16 It is also significant to see in the following 17line, my Lord, I have written the words "truppenschuhe", 18and this is another misreading by me. 19MR JUSTICE GRAY: It does not really matter, does it. 20MR IRVING: My Lord, I am just trying to say as you will see 21from the next page, which I now ask you to turn. 22MR JUSTICE GRAY: Before you leave that, I thought there was 23another point made on this document, which is your 24translation of the words -- 25MR IRVING: That is Verwallueys Fuhrer. 26MR JUSTICE GRAY: Am I not right about that?

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1MR IRVING: This was the point Mr Rampton sought to make, and 2I corrected him, my Lord, and said that was not the word 3that I misread. It was the word on the following line 4haben, which I misread as Juden, and this is why I was 5going to ask your Lordship, respectfully, to turn to the 6next page, page 14, where you will see the words in 7question, three lines from the bottom on the right, that 8is the quality of the original I was working from. I do 9not know if your copy is highlighted, the crucial word is 10not perhaps... 11MR JUSTICE GRAY: Yes, it is. What did you originally 12transcribe that as? 13MR IRVING: Juden, I would submit this is a perfectly 14reasonable kind of mistake to make. If I was to labour 15the point I would draw your Lordship's attention to all 16the other versions of the word "Juden" that are correct, 17you will see they are very similar indeed in the German 18Gothic handwriting. 19 So what we have, my Lord, to recap at this 20point, November 30th Himmler for some reason in a 21telephone conversation with Heydrich saying that train 22load of Jews from Berlin is not to be liquidated. 23I believe that is a fair expansion of that sentence. 24 On the following day he has that telephone 25conversation with SS Gruppen Fuhrer Poll, I am back on 26page 13, at 4.45 p.m. They touch on Depervartens (?)

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1Fuhrer, but more important now is the conversation, again, 2with Heydrich about the same time as the previous one, on 3the previous day, 13.15 on that page 13. He has a 4conversation with Prague first of all about his scribes, 5the female scribes and, secondly, "executionen", like 6"executions", in Riga. I am sure I do not have to 7translate that. So it is now very much in the air that 8something has gone on in Riga, my Lord. 9 On page 15, that same day, we are well in the 10chronology, my Lord, this is a telephone conversation at 117.15 a.m. on that Monday morning, December 1st, 1941. 12This is coming from Jeckelm to Berlin. This is a very 13ugly one indeed, my Lord. He is saying in English: 14"I need by next available air courier 10 Finnish", 15Finland, in other words, "military pistols with two drum 16magazines each. Execution of sonder aktionen", special 17actions, S-O-N-D-E-R A-K-T-I-O-A-N, "request radio 18telegramme reply. Senior SS and Police Command, North 19Russia". 20MR JUSTICE GRAY: Who is this addressed to in Berlin then? 21MR IRVING: The main leadership Hauptamt, would be the body 22concerned with the procurement of such armaments. The 23significance of this, my Lord, if you remember the 24harrowing description by General Bruns of the shootings on 25the edge of the pit where the men were using machine guns, 26tommy-guns, and he has run, he has not enough tommy-guns,

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1he needs more. You can see the actual intercept of that, 2my Lord, on the next page. 3 What is the answer he gets? Page 17, again my 4translation my Lord, Himmler himself contacts him, either 5in person, that is the second message, or through his 6Adjutant, Grothmann (who is still alive in Germany now). 7He sends this message to that same criminal, Jeckelm, at 87.30 p.m. on December 1st: To SS Obergruppenfuhrer 9Jeckelm, Senior SS and Police Commander, Osla, Riga. 10Reichfuhrer SS Himmler summons you to him for a conference 11on December 4th. Please state when you will arrive here 12and by what means you will be travelling". In other 13words, he had been summoned urgently to the Headquarters. 14The very next message explains what is going to happen. 15"SS Obergruppenfuhrer Jeckelm" -- this is the message we 16dealt with yesterday, my Lord -- "The Jews being outplaced 17to Osland", to the Baltic, "are to be dealt with only in 18accordance with the guidelines laid down by myself and/or 19by the ... (reading to the words) ... on my orders. 20I would punish arbitrary and disobedient acts", signed 21Himmler. A most incredibly important message, I think, 22for many reasons. He is not talking about a Hitler order 23here. He is saying: "The guidelines issued by me", by 24Himmler, "or by the Reichssicherheits Hauptamt" who is 25Heydrich", his telephone conversation partner. Jeckelm, 26out on the Eastern front, has overstepped the guidelines.

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1He started shooting thousands of Germans. He had been 2summoned to Himmler's headquarters, to Rastenburg, in East 3Prussia to account for himself. 4MR JUSTICE GRAY: Where do we find the guideline? 5MR IRVING: My Lord, we will hear in the course of this trial 6that these intercepts are not wall to wall. We do not 7have everything that they sent. There is an enormous mass 8of trivia, people whose cars have been towed and that kind 9of thing, people whose wives have died. Occasionally 10embedded in the trivia, like in a goldmine, in the slurry, 11there are diamonds like this. 12 The incredible thing is, although this document 13has now been in the public domain for about five or six 14years, the historians and the world have not leapt on this 15document and said,"Irving was right. This proves that the 16Fuhrer's headquarters were not only indignant, but were 17calling people to account. In the way that the wars are, 18although he is brought back from the Front and he is 19wrapped on the knuckles, he is sent back to the Front to 20carry on with his job. He is not dismissed from service; 21in rather the same way as I know General Patten, for 22example, went to the Front when General Patten had been 23liquidating prisoners. He was called before Eisenhauer 24and called to account. He was put on ice for two or three 25months and then he was given command of one of the best 26armies, the 3rd American Army, because good men are hard

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1to come by in a war. That is, undoubtedly, the way the 2Nazis viewed this criminal. 3 May I proceed, my Lord? 4MR JUSTICE GRAY: Yes, thank you. 5MR IRVING: We can see on page 21 the arrival of the 6unfortunate criminal, the arrival of the unfortunate 7criminal, SS Obbergruppenfuhrer Jeckelm in Himmler's 8appointment book, in other words, at Hitler's 9headquarters. One notices at 1300 they are driving over 10Hitler's headquarters. Then Himmler visits the barber and 11the dentist. He sees Hitler at 5 p.m. and at 7 p.m. he 12sees other SS Generals. At 8 p.m. he has dinner in part 13of Hitler's headquarters with Jeckelm and at 9.30 he hauls 14Jeckelm over the carpet, the Jewish question, the SS 15brigade, economic business. So that is the actual visit. 16MR JUSTICE GRAY: Would it be a fair interpretation of this 17document that the original plan was that Jeckelm should be 18present with Hitler and Himmler at 5 o'clock in the 19afternoon? 20MR IRVING: I cannot be specific on that, my Lord. 21MR JUSTICE GRAY: It looks like it, does it not? 22MR IRVING: I do not want to speculate, but these are grey 23areas. The documents do not tell us everything we would 24dearly love to know. What we do know is the final two 25pages I put in the bundle. My Lord, you will see that the 26last page has some red print on the bottom, the very last

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1page. This is the German, I would say, official 2transcript of Himmler's diary which, my Lord, the 3Defendants also have on the desk in front of them. It is 4published this year. It is enormously expensive. It is a 5very good and highly dependable transcription of Himmler's 6diaries and appointment book. 7 They put that in as a footnote at 104, 8I believe, in which they say: "After these signals were 9exchanged", which, oddly enough, they do not elucidate to 10the degree that I have, "the killings of German Jews 11stopped for many months". I have no further submissions 12to make about these documents. 13MR JUSTICE GRAY: You have lost me a little. Where do I find 14after these messages ---- 15MR IRVING: The very last line of the red text. This is the 16comments by the editors, who are a team of German 17historians, on the Himmler diaries which they have 18annotated most expertly, and they too have drawn finally 19on these two mysterious messages that we intercepted. 20MR JUSTICE GRAY: But the point that may be made, I do not 21know, on this is that it is the mass shootings of German 22Jews that ceased. 23MR IRVING: I agree, my Lord. This is why I have been very 24careful to make a distinction in my evidence and, indeed, 25in my books. 26MR JUSTICE GRAY: That suggests to me -- tell me if I am wrong

. P-23

1about this -- that the guidelines mentioned in the earlier 2message were guidelines relating to German Jews. 3MR IRVING: This is quite possible, my Lord. I would only ask 4you in reading, as undoubtedly you will, and re-reading 5passages from my books on which the Defendants seek to 6rely, you ask yourself this question, has Mr Irving, the 7so-called Holocaust denier, at any time implied that this 8kind of massacre did not go on, and that it was systematic 9and it was carried out on guidelines from above? 10MR JUSTICE GRAY: Yes. 11MR IRVING: But you will notice that Mr Himmler talks about 12"orders that I have issued and the Reichssicherheits 13Hauptamt". He never says, "On the Fuhrer's instructions" 14which, obviously, there would be a strong temptation in a 15message like this to say, "You have not only upset me, but 16you have put Adolf's nose really out of joint". 17 So, I mean, obviously, I am going to submit that 18if documents like this exist of a quality like that, to 19imply that I was speaking off the wall in some way with no 20kind of documentary basis for the submissions that I make 21in my books, it would be unfair, unjust and perverse. 22MR JUSTICE GRAY: Yes. You have taken me through, and thank 23you for that ---- 24MR IRVING: I ---- 25MR JUSTICE GRAY: --- this little bundle. I am making this 26point at this stage because it is going to crop up time

. P-24

1and again. I am rather anxious not to have little one 2issue bundles cropping up at odd stages because, frankly, 3in a case of this length, it is all going to get lost and 4tangled. I imagine that all these documents are in one or 5other of the existing files. 6MR IRVING: They are in this cover, my Lord, but not in such 7pristine condition as that. I want to very great trouble 8last night to prepare this particular bundle in the hope 9that you would say to yourself, well, if he was able to 10come up with evidence like this on this matter, no doubt 11he will be able on any other matter ---- 12MR JUSTICE GRAY: Do not misunderstand me. I am not critical. 13I think it is helpful to have a bundle prepared like this, 14but what I need to be sure of is that I know where these 15documents can be found in the existing files. What I will 16ask somebody on the Defendants' side to do, if they would 17be good enough, if they can do this, is to provide me with 18the cross-reference. Could you ask somebody to do that? 19MR RAMPTON: We will think about that. The trouble is at the 20moment that our files are ordered according to the 21experts' reports. 22MR JUSTICE GRAY: Yes, but most of these documents would be 23relatively easily traced? 24MR RAMPTON: Most of them, I think, are referred to in the 25expert reports anyway. Whether they are copied in quite 26that form, I am not sure; I think probably not.

. P-25

1MR JUSTICE GRAY: You see why I need to have what I am asking 2for. 3MR RAMPTON: Yes, I do. My immediate idea is just to put them 4with a separate numeration at the back of Professor 5Browning or that report. It is apparently ---- 6MR JUSTICE GRAY: I think that is not a bad idea, to put them 7into J, otherwise there is going to be proliferation of... 8MR IRVING: My Lord, I am using an alphabetical system which 9requires that there are going to be less than 26 such 10files over the entire case that I would anticipate putting 11in of this nature. If you will bear with me, the reason 12I called this just "Himmler" is that I was intending to 13produce further documents, for example, the Schlegelberger 14series (which I am sure your Lordship is familiar with). 15I would also put that into that binder. So there will 16just be an Irving series, Irving A, Irving B, Irving C. 17This is, after all, my case, my Lord, and I do not want my 18structure to be subsumed into the case for the Defendants. 19MR JUSTICE GRAY: I entirely agree with that. This may all 20seem very boring, but, believe me, in a case like this you 21---- 22MR IRVING: "Boring" is not a word I would use. 23MR JUSTICE GRAY: --- really do have to watch the sort of 24housekeeping. Just so that everybody knows where I have 25it, I am putting it into J. 26MR RAMPTON: Tab C.

. P-26

1MR JUSTICE GRAY: I have not got a tab C. 2MR IRVING: My Lord, I would propose that we now continue where 3we left off last night. 4MR JUSTICE GRAY: I am going to treat what you have told me in 5the last 20 minutes or so as being part of your evidence, 6although you told me from counsel's bench. It is up to 7you; I think you probably ought to go back, if you would 8be good enough, into the witness box. 9 Cross-examined by MR RAMPTON, QC, continued. 10THE WITNESS: My Lord, there is just one other document there 11that I forgot to refer to and this is No. 23. I will just 12read it out to you. There is no need for your Lordship to 13see it. 14MR JUSTICE GRAY: I had better follow it. 15A.
[Mr Irving]
A telephone conversation of exactly the same kind from 16Himmler's telephone log: On Hitler's birthday, at midday 17with Heydrich, again that is H-E-Y-D-I-C-H, a 18conversation with Heydrich in which the last line reads: 19"Kindly", "Keine vernichtungd. Zigeuner", K-E-I-N-E 20V-E-R-N-I-C-H-T-U-N-G-D. Z-I-G-E-U-N-E-R. 21Q.
[Mr Justice Gray]
That is "gypsies", is it not? 22A.
[Mr Irving]
That is right, my Lord. 23Q.
[Mr Rampton]
How would you translate "vernichtungd"? 24A.
[Mr Irving]
Literally "destruction" and that is how I will leave it. 25"No destruction of the gypsies"; the significance being 26that on this day at mid-day, Himmler is with Hitler

. P-27

1celebrating a birthday party. It was Hitler's birthday, 2April 20th. Once again he has had to telephone his chief 3executioner, so to speak, Heydrich, and say, "The gypsies 4are not to be liquidated" and yet they were liquidated. 5Q.
[Mr Rampton]
You say Himmler was with Hitler at 12 o'clock? 6A.
[Mr Irving]
Quite definitely. It was Hitler's birthday and I would be 7happy to lead evidence to prove that, but I am sure 8Mr Rampton will not dispute that the head of the SS ---- 9Q.
[Mr Rampton]
And this is a phone call to Heydrich from Himmler? 10A.
[Mr Irving]
It is a telephone conversation between them. 11Q.
[Mr Rampton]
Yes, I take that point. 12A.
[Mr Irving]
Of significance, it is one more document in that chain 13that I occasionally refer to. 14MR JUSTICE GRAY: Thank you. 15MR RAMPTON: Yes, as to that, Mr Irving, the "no liquidation of 16the gypsies", again that was before there was any meeting 17between them, was it not, on that day, which is 20th April 181942, Himmler's log said that he met Fuhrer at 12.30? 19A.
[Mr Irving]
This may well be. It may well be what his log says. 20Q.
[Mr Rampton]
Whereas the telephone call is at noon, I think. 21A.
[Mr Irving]
Yes. 22Q.
[Mr Rampton]
Rather like 30th November? 23A.
[Mr Irving]
Yes. 24Q.
[Mr Rampton]
1941? 25A.
[Mr Irving]
Yes. 26Q.
[Mr Rampton]
Can we go back to 30th November 1941, please? Did you get

. P-28

1a transcript of your evidence of the proceedings 2yesterday -- have you got a copy that looks like this, 3Mr Irving? 4A.
[Mr Irving]
Yes I have. 5Q.
[Mr Rampton]
With a quarter page like that? 6A.
[Mr Irving]
Yes. 7Q.
[Mr Rampton]
Could you turn, please, to the page numbered 289? It is 8the top left-hand block on one of the pages. 9A.
[Mr Irving]
Yes. 10Q.
[Mr Rampton]
I was asking you if you remember why it was that you had 11translated "Judentransport", a singular word, as Jews in 12general? 13A.
[Mr Irving]
Yes. 14Q.
[Mr Rampton]
You had said, you can see it there, can you not, that it 15was a silly misreading of the word. You said at line 19: 16"I admit I made a mistake in the transcription"? 17A.
[Mr Irving]
Yes. 18Q.
[Mr Rampton]
This was your sworn evidence on oath yesterday? 19A.
[Mr Irving]
Yes. 20Q.
[Mr Rampton]
Now would you please turn to the first page of your new 21bundle? 22A.
[Mr Irving]
Yes. 23Q.
[Mr Rampton]
The translation you have made for us kindly ---- 24A.
[Mr Irving]
Yes. 25Q.
[Mr Rampton]
--- 23rd January 1974, where you have transcribed it 26correctly?

. P-29

1A.
[Mr Irving]
Yes. 2Q.
[Mr Rampton]
The answer you gave yesterday was wrong, was it not? 3A.
[Mr Irving]
That is correct. 4Q.
[Mr Rampton]
Why was it wrong, Mr Irving? 5A.
[Mr Irving]
Because we are talking about events almost 30 years ago. 6I was writing this book 32 years ago. I received these 7documents 35 years ago. I probably transcribed it, as you 8can see from the letter, round about 1974. It is very 9difficult to put myself back into my mind set of 25 or 26 10years ago. 11 You asked me what the reason for that was and 12my first presumption was that I misread the word, but ably 13challenged by his Lordship, questioned by his Lordship, on 14this matter, I recalled also that at the time I looked at 15it, the word "transport", "Judentransport", to me also 16could be translated as "transportation of Jews". Indeed, 17it can be translated that way and I refined it later on 18when I was informed by Dr Flemming, as he then was, who is 19an expert on the Holocaust, that there was one very clear 20train load of Jews to which reference was being made. 21That is so, I think, an accurate answer which should 22really replace yesterday's answer. 23Q.
[Mr Rampton]
I dare say it should, Mr Irving. Whether I accept it, of 24course, is quite another question, even in its remodelled 25form. 26A.
[Mr Irving]
Yes.

. P-30

1Q.
[Mr Rampton]
The answer is, of course, that I do not. Mr Irving, 2I would like you to think a little bit about what you have 3just said. You heard me open this case on Tuesday 4afternoon, did you not? 5A.
[Mr Irving]
Yes. 6Q.
[Mr Rampton]
Yes. You have to say "yes" just for the recording. That 7is all. Nodding or so will not do. You had a copy of the 8written document that I read out, did you not? 9A.
[Mr Irving]
Which document are you referring to? 10Q.
[Mr Rampton]
My opening statement in this case? 11A.
[Mr Irving]
Yes. 12Q.
[Mr Rampton]
That was on Tuesday afternoon. 13A.
[Mr Irving]
Yes. 14Q.
[Mr Rampton]
You realized then ---- 15A.
[Mr Irving]
Yes. 16Q.
[Mr Rampton]
--- that this is one of the points that I was going to 17make against you, did you not? 18A.
[Mr Irving]
Yes, that has been repeatedly made, yes. 19Q.
[Mr Rampton]
It has been repeatedly made, has it not? Yet, when you 20come into the witness box to answer questions on oath, you 21simply pluck an explanation out of the air, do you not? 22A.
[Mr Irving]
Mr Rampton, may I explain to you that in the last four 23days I have had six hours sleep? Is this a satisfactory 24answer to why one occasionally makes slips of the memory 25in the witness box? If not, then I will go into it in 26greater detail.

. P-31

1Q.
[Mr Rampton]
What is the truth, Mr Irving? You did not misread it, 2that is clear. 3A.
[Mr Irving]
Yes -- not this particular word. 4Q.
[Mr Rampton]
No. So yesterday's answer was a false answer. 5A.
[Mr Irving]
Misinterpreted. 6Q.
[Mr Rampton]
You now say, "Well, I may have mistranslated it, but my 7translation was, on the face of it, legitimate"? 8A.
[Mr Irving]
Well, in this case it is not a translation that is needed, 9it is an interpretation because it is a cryptic word. 10"Transport" can mean several different things. There are 11many words that can mean several different things, and you 12have to look at the context and you have to take other 13documents and possibly later information into account in 14arriving at which of those words is the correct 15translation. None of the words would be a wrong 16translation at the time you first make it. You then 17refine the translation on the basis of external evidence. 18Q.
[Mr Rampton]
Would not a more natural way of putting it in German to be 19to put it in the plural "Judentransporte" with an "e" on 20the end? 21A.
[Mr Irving]
It can also be done that way, yes. 22MR JUSTICE GRAY: Would part of the context be that there did 23happen at this time to be a train load of Jews setting out 24from Berlin to Riga? 25A.
[Mr Irving]
There were many train loads sitting out. By this time, by 26November 30th, there had been five trainloads of Jews

. P-32

1heading for Riga or Minsk. 2Q.
[Mr Justice Gray]
Over what sort of period? 3A.
[Mr Irving]
One week, round about that time -- no, I am sorry, two 4weeks would be a closer approximation. They were given 5numbers, "D" for Germany, "O" for East or German, rather, 6and "O" for East. That is what the numbers in the 7intercepts are. 8MR RAMPTON: Mr Irving, another of the things that you and 9I disagreed about yesterday was your unequivocal 10categorical assertion in your various publications that 11that order from Himmler to Heydrich on that day was given 12at the instigation of Hitler. You say it was, or at least 13that is a reasonable inference; you called it a "judgment 14call", I think, did you not? 15A.
[Mr Irving]
I called that, the reason I used it, or referred to it in 16that -- I think we ought to see the actual wording 17I used. If you say that I said it on a number of 18occasions, it would be helpful to see the actual wording 19that I used. 20Q.
[Mr Rampton]
For example, let us just look at how you put it in 21"Hitler's War 1991". My Lord, that is bundle D1(v). It 22is in two halves. This is the second half. At page 427, 23Mr Irving, if you are using the published edition? 24A.
[Mr Irving]
I am just looking at the 1977 one to pre-empt you. 25Q.
[Mr Rampton]
We will look at that first, if you will. I think there it 26is round about 300 and something.

. P-33

1A.
[Mr Irving]
At 1.30 p.m. 2Q.
[Mr Rampton]
Well, his Lordship may not have it. 3MR JUSTICE GRAY: Yes, I have. 4MR RAMPTON: Have you got 1977, my Lord? 332. 5A.
[Mr Irving]
Yes. I think, with respect, it makes more sense to take 6it from the chronology that I wrote the various editions. 7Q.
[Mr Rampton]
I was not actually going to look at all the references, 8but if you wish me to do so, I do not mind in the 9slightest. 10A.
[Mr Irving]
Well, it is like a building, the way a building changes 11over the years, that tells us something also. 12Q.
[Mr Rampton]
"Himmler's personal role is ambivalent. On November 30th 131941, he was summoned to the Wolf's Lair for a secret 14conference with Hitler in which the fate of Berlin's Jews 15was clearly raised". Pause there. What evidence that 16Himmler was summoned to the Wolfsschanze the Wolf's Lair? 17A.
[Mr Irving]
My very great expertise on this matter. 18Q.
[Mr Rampton]
What? 19A.
[Mr Irving]
My very great expertise on this matter. Do you wish me to 20elaborate? 21MR JUSTICE GRAY: Yes, I think you had better; I am not quite 22sure I understand the answer. 23MR RAMPTON: I asked for evidence, not expertise. 24A.
[Mr Irving]
Well, the evidence is that if you go to the archives and 25work through the files of Hitler's Chancellory, you will 26find every year, two or three times, the head of his

. P-34

1Chancellory, Hans Lammers, issued an edict to all the 2Reich ministers and all the senior Nazi officials 3informing them that nobody was permitted to visit Hitler, 4just ringing the door bell and saying, "Mein Fuhrer, can 5I drop in and see you for a moment?" They had to have a 6specific summons and invitation because Hitler was 7constantly being beseiged by junior and senior officials 8who were ringing his doorbell in that way and asking to 9see him. Eventually, it had to be forbidden, first of all, 10by Lammers and then by an edit of Martin Bormann. So you 11could not visit Hitler unless you were summoned. 12Q.
[Mr Rampton]
Mr Irving, I am not going away from that topic, believe 13me, I am not, but it may be we had better get this sorted 14out earlier rather than later in this case. Where do you 15place Himmler in the Nazi hierarchy? 16A.
[Mr Irving]
Nowhere in the hierarchy that it would just turn up on 17Hitler's doorstep. 18Q.
[Mr Rampton]
Please, we will come to that I promise I not leaving the 19topic, where do you put him? 20A.
[Mr Irving]
He had the rank of a Reichsminister, the rank of 21Reischminister was equivalent to a field marshal, so it 22would be the equivalent rank of four star general. He had 23Hitler's ear, he took orders directly from Hitler, there 24was no intermediary, is that sufficient? 25Q.
[Mr Rampton]
-- yes, I am going to go a little bit further. This is 26not hostile interrogation, Mr Irving, this is an attempt

. P-35

1to see if we can agree on some broad general facts which 2may be of use in this case. Himmler was, was he not, one 3of the original putschists of 1923? 4A.
[Mr Irving]
He is there to be seen marching in the ranks. 5Q.
[Mr Rampton]
Wearing Nazi uniform. 6A.
[Mr Irving]
One of the old guard. 7Q.
[Mr Rampton]
Have you read Ian Kershaw's book? 8A.
[Mr Irving]
Whose? 9Q.
[Mr Rampton]
Ian Kershaw's book? 10A.
[Mr Irving]
I do not read books. 11Q.
[Mr Rampton]
You do not read books. Of course not. He is one of old 12guard, is he not? 13A.
[Mr Irving]
Yes. 14Q.
[Mr Rampton]
So was Goring? 15A.
[Mr Irving]
Yes. 16Q.
[Mr Rampton]
And so was Goebbels? 17A.
[Mr Irving]
On and off, if you see what I mean. 18Q.
[Mr Rampton]
Yes, I do see what you mean. Is there anything which 19leads you to suppose -- 20A.
[Mr Irving]
In connection with Goebbels, of course, he was not one of 21the putschists, he came in several years later. 22Q.
[Mr Rampton]
-- Rosenberg was perhaps, I do not know. Is there 23anything you know of that prevents one from supposing that 24Hitler might have telephoned as he apparently was able to 25use the telephone on the train, was he not? 26A.
[Mr Irving]
Himmler, you are talking about?

. P-36

1Q.
[Mr Rampton]
Himmler I mean, telephoned the Wolf's Lair and said "can 2I come and talk to you about something"? 3A.
[Mr Irving]
No reason to suppose that at all, yes. 4Q.
[Mr Rampton]
So why you do use the word "summon"? 5A.
[Mr Irving]
Because then Hitler would have said "all right, come and 6see me". 7Q.
[Mr Rampton]
You see in the context, do you agree, the word "summoned"? 8A.
[Mr Irving]
Yes. 9Q.
[Mr Rampton]
Means that he is being summoned in order to discuss the 10fate of the Berlin Jews? 11A.
[Mr Irving]
In the context. 12Q.
[Mr Rampton]
Yes. Amongst other things, perhaps? 13A.
[Mr Irving]
No, I disagree with you Mr Rampton, on November 30th, he, 14Himmler was summoned to the Wolf's Lair for a secret 15conference with Hitler at which the fate of Berlin's Jews 16was clearly raised. 17Q.
[Mr Rampton]
By whom? 18A.
[Mr Irving]
We do not know. 19Q.
[Mr Rampton]
Then you go on, at 1.30 p.m. Himmler was obliged to 20telephone from Hitler's bunker? 21A.
[Mr Irving]
Yes. 22Q.
[Mr Rampton]
Who could have obliged, that is to say compel, Himmler to 23do such a thing? 24A.
[Mr Irving]
His own inner conscience. 25Q.
[Mr Rampton]
That is what it was, was it? 26A.
[Mr Irving]
That is why I used word "obliged" otherwise I would have

. P-37

1said "ordered". 2MR JUSTICE GRAY: The reality of the way, would you not 3accept, Mr Irving, of the way it is put in your book is 4that the reader is going to infer that that was an order 5from Hitler to him? 6A.
[Mr Irving]
My Lord, I use my words with utmost care when I write 7passages like that. I will go backwards and forwards over 8them looking for a word which I considered to be justified 9by the evidence but not implying or imputing or inferring 10too much. If I used the word "obliged" then it was 11because I hesitated to use the word "order" but for some 12reason he made the telephone conversation. He did not 13wait until he got back to his own headquarters, he 14immediately phoned Heydrich from Hitler's bunker without 15even getting over to the local phone box, he phoned 16Heydrich with these instructions saying "stop the 17killing". 18MR RAMPTON: That is what you intended to convey in that 19passage of that page of Hitler's War 1977? 20A.
[Mr Irving]
That is all that I felt it was safe to convey on the basis 21of the very skimpy evidence I had at that time. At that 22time, of course, I did not even have the decodes, but now 23the decodes confirm me. 24Q.
[Mr Rampton]
So you say. Let us turn to page (xiv) of the introduction 25to this book, may we? 26A.
[Mr Irving]
Yes.

. P-38

1Q.
[Mr Rampton]
Perhaps for completeness start at the bottom of page 213: "Many people, particularly in Germany and Austria had 3an interest in propagating the accepted version of the 4order of one mad man originated the entire massacre." We 5are talking here about Holocaust in the old sense, old, in 6the Irving history. 7MR JUSTICE GRAY: I am so sorry, Mr Rampton, I am lost, page 813. 9MR RAMPTON: (Xiii) of the introduction. 10MR JUSTICE GRAY: Thank you. 11MR RAMPTON: I will start again. Last two lines bottom of page 1213: "Many people, particularly in Germany and Austria had 13an interest in propagating the accepted version that the 14order of one mad man originated the entire massacre." That 15is to say the massacre of the Jews, those are my words, my 16Lord. "Precisely when the order was given in what form 17has admittedly never been established. In 1939? But the 18secret extermination did not begin operating until 19December 1941. At the January 1942 Bunzig conference? 20But the incontrovertible evidence is", note those words, 21Mr Irving, in the light of your recent answers, "the 22incontrovertible evidence is that Hitler ordered on 23November 30th 1941 that there was to be 'no liquidation' 24of the Jews (without much difficulty I found in Himmler's 25private files his own handwritten note on this)." In the 26light of that, Mr Irving, would you care to revise the

. P-39

1answers you gave a moment ago? 2A.
[Mr Irving]
No. 3Q.
[Mr Rampton]
Well, what do those words mean? Do they speak for 4themselves or do they not, that I have just read? 5A.
[Mr Irving]
I have done exactly what any normal editor would do, you 6present the evidence and then you draw conclusions. 7I present the evidence in the body of the book. I even in 8this one case print a facsimile of the document which is 9pivotal to this particular argument and then in the 10introduction (as a good author should) I put my principal 11conclusions. Here I am putting my principal conclusion as 12the author, David Irving, that I draw the conclusion from 13this episode that Hitler had intervened to stop -- and 14here is the error, the liquidation of the Jews. What 15I should have written is "the liquidation of a transport 16of Jews". That was the state of my knowledge at the time 17I wrote this version of this book. Subsequently of course 18I amended it. 19Q.
[Mr Rampton]
I think you told me yesterday that the only evidence you 20had for the order of Hitler was that Himmler was there at 21the time? 22A.
[Mr Irving]
The only evidence that I had for an order of Hitler? 23Q.
[Mr Rampton]
Yes, was that Himmler was at the Wolfsschanze at the time? 24A.
[Mr Irving]
I think we would have to see exactly what I testified 25before I would agree to that brief summary. 26MR JUSTICE GRAY: I think it is right, but if you want to be

. P-40

1referred to it then no doubt you should be. 2MR RAMPTON: A summary? 3A.
[Mr Irving]
I hate to agree with vulgarised versions of what I 4testified. 5MR JUSTICE GRAY: Let us have a look and see what you did say. 6MR RAMPTON: My Lord, one could start at line 20 on page 285 7perhaps? 8A.
[Mr Irving]
285? 9Q.
[Mr Rampton]
285, line 20, I am trying not to take too much of it. 10I suppose it really begins at line five on page 285, but 11I hope I summarized it fairly? 12A.
[Mr Irving]
I do not think you did, but I will certainly stand by what 13I stated on those two pages. 14MR JUSTICE GRAY: Look at line 286, line 3 and onwards. 15MR RAMPTON: Yes, please. 16A.
[Mr Irving]
This is the question, of course, and not the answer. 17MR JUSTICE GRAY: Yes, but there is an answer after the 18question. 19MR RAMPTON: At line nine there is an answer. 20A.
[Mr Irving]
Yes. 21Q.
[Mr Rampton]
My summary was a fair one. There is no evidence beyond 22the fact that Himmler was at the bunker that day and had 23lunch with Hitler an hour later, is there? 24A.
[Mr Irving]
Evidence for what? 25Q.
[Mr Rampton]
For an order from Hitler that Jews -- that the train load 26of Jews, let us stick with that for the moment?

. P-41

1A.
[Mr Irving]
This is -- 2Q.
[Mr Rampton]
Should be not liquidated? 3A.
[Mr Irving]
-- I do not mean this offensively, but this is the common 4sense interpretation of the evidence lying before us, 5rather the perverse interpretation. We will always has 6versions or two interpretations, one is the obvious one, 7which is -- and the other is the perverse one. The 8obvious one is if Himmler goes to Hitler's headquarters 9and is handed a phone at some time on his way out and he 10then has to make phone call to Heydrich saying, "stop 11killing the Berlin Jews", then there is some close 12connection between that and the fact he has seen Hitler 13that day. 14Q.
[Mr Rampton]
That is a possible interpretation, we in this court, and 15I do not know about the court of history, we in this court 16when we say "evidence" we mean "evidence" not "inference". 17A.
[Mr Irving]
The issues that are being pleaded are mistranslation, or 18distortion, deliberately mistranslation, distortion, 19manipulation and I do not think that the particular avenue 20we are going down leads in the -- 21Q.
[Mr Rampton]
I will put it bluntly to you and then I will leave it, you 22can deny it, because you will deny it, I am sure; (a) you 23deliberately mistranslated it, you inflated from one train 24load into Jews generally, that is number one; and (b) you 25inserted an order from Hitler for which there was no 26evidence?

. P-42

1A.
[Mr Irving]
-- I will take those two allegations seriatim; that 2I inflated it deliberately, there is not a shred of 3evidence for that. The evidence is quite clear, that as 4soon as Dr General Flemming brought to me the evidence 5there was one train load of Jews which was in trouble that 6day, I immediately and in subsequent editions of the book 7revised it to the narrow interpretation of the word 8"transport" rather than the wider interpretation. 9Q.
[Mr Rampton]
And you are sticking with the Hitler order answer? 10A.
[Mr Irving]
As being the reasonable rather than perverse analysis of 11the documents at that time before us. I emphasise of 12course it has now been very amply confirmed by the 13intercepts I read out in my bundle this morning. 14Q.
[Mr Rampton]
Very well, then, we must look at another document. This 15is one of your documents? 16MR JUSTICE GRAY: Before you do can I ask one rather mundane 17question. 18MR RAMPTON: Yes, of course. 19MR JUSTICE GRAY: But I think you will understand why I ask it, 20Hitler's headquarters or the Wolf's Lair, how big a 21building or collection of buildings was that? 22A.
[Mr Irving]
At that time it was not a big formidable complex which 23exists today, huge concrete bunkers. There were one or two 24air raid shelters, but it was mostly in the form of wooden 25barracks scattered around in a compound of a 2 or 3 26kilometres area with minefields and forests.

. P-43

1Q.
[Mr Justice Gray]
How many people would work there? 2A.
[Mr Irving]
Probably in the order of one thousand people including all 3the escorts and security. It had various inner areas and 4so called "sperrkreise", which were the security zones and 5he was in security zone A. But if it is ausdembunker, 6from the bunker, then it is from Hitler's bunker. 7MR JUSTICE GRAY: By which you mean an office or -- 8A.
[Mr Irving]
No, Hitler -- 9Q.
[Mr Justice Gray]
-- a part of the compound where Hitler was himself based? 10A.
[Mr Irving]
-- in the security zone A there was the bunker in which 11Hitler resided, lived and conducted his conferences. 12Later on it was massively reinforced after the Allied air 13raids started. 14MR RAMPTON: This is all on the same topic, Mr Irving, so that 15the document you are will next need is to be found in 16bundle D8(iii), somebody will give it to you (same 17handed). 18A.
[Mr Irving]
Very well. 19Q.
[Mr Rampton]
The page I want is 1042. 20A.
[Mr Irving]
Yes. 21Q.
[Mr Rampton]
At the same time could I give you and his Lordship -- 22I have composed a page of the reprinted Himmler logs for 23Sunday 30th November 1941 and Monday 1st December 1941, 24I have taken from that Witte book. I have taken out the 25footnotes because I wanted the text. I wanted the text to 26appear unvarnished. First of all would like you to look

. P-44

1at the page in D8(iii) page in D8(iii), 1042. This is 2taken from your website; do you recognize it? 3A.
[Mr Irving]
Yes. 4Q.
[Mr Rampton]
You do, Mr Irving. At the bottom of the page the last 5entry starts: Meanwhile another page from the Himmler file 6in the Moscow archives obtained by David Irving on Sunday 7May 17th 1998, reveals the Reischsfuhrer's appointments 8for November 30th 1941, see above. The day of the 9telephone call with Heydrich". 10 Turn over now to page 1043. 11 "This suggests that Mr Irving's original theory 12that Himmler discussed the matter with Hitler before 13phoning Heydrich is wrong. Himmler saw SS Sturmbannfuhrer 14Gunther d'Alquen, a journalist, from 12 to 1 p.m. 15(Reisebericht uber SS Pol Division [that is short for 16politzei] u. [that is an abbreviated U stop] 17Totenkopfdivision) then worked for an hour 18('gearbeitet') during which he made the phone call, 19received General Dietl from 2 to 2.30 p.m." I will not 20bother to read the next bit. 21 "And only then, at 2.30 p.m., went for lunch 22until 4 p.m. with Hitler ('Mittagessen b. Fuhrer') that is 23short for bei, yes ? 24A.
[Mr Irving]
Yes. 25Q.
[Mr Rampton]
That is your account, must postdate the 17th May 1998, 26must it not? According to that entry anyway it does, if

. P-45

1you look at the first page? 2A.
[Mr Irving]
Yes. I did not understand the question, last question, it 3was what? 4Q.
[Mr Rampton]
Well, if you say that you arrive at this conclusion in 5consequence of the discovery of a Himmler, a file page on 617th May 1998, this, what shall we say, "confession" must 7postdate that, must it not? 8A.
[Mr Irving]
Perhaps I should explain to his Lordship, if your Lordship 9is wondering why it is written in the third person. This 10is a page. 11MR JUSTICE GRAY: I do not think that matters at all. 12A.
[Mr Irving]
No, right. But in other words I wrote that. This is what 13is important. 14Q.
[Mr Justice Gray]
I follow you wrote it. 15MR RAMPTON: I had assumed you wrote that. This is why I called 16it a confession. 17A.
[Mr Irving]
Confession implies that something is wrong. 18MR JUSTICE GRAY: Put the substance, Mr Rampton. 19MR RAMPTON: It is quite inconsistent with the version you have 20been giving us in this court? 21A.
[Mr Irving]
It is absolutely consistent with my methods as an 22historian as saying here is one version, but the audience 23should know there is an alternative version. This is 24absolutely consistent with -- you remember how I sent that 25letter to The Times in 1966 saying there are other figures 26on Dresden and it is right that the public knows this.

. P-46

1I know it is unusual for historians to do this, but I do 2that kind of thing. 3Q.
[Mr Rampton]
But you did not say, but on reflection I think this 4suggestion that I was mistaken is probably wrong, and 5I adhere to my original thesis that it was a Hitler order? 6A.
[Mr Irving]
I draw attention to the first two words on page 1043 "this 7suggests". 8Q.
[Mr Rampton]
I know that? 9A.
[Mr Irving]
It does not say "this confirms" or "proves". 10MR JUSTICE GRAY: But to be blunt about it, Mr Irving, what 11I think is the suggestion made on the basis of your 12website entry is that it was because a journalist tipped 13off Himmler what had been going on that the message went 14out to Riga; have I understood it correctly? 15A.
[Mr Irving]
I think I would be reading very much between the lines, my 16Lord. 17Q.
[Mr Justice Gray]
That is what you are saying here, is it not, Mr Irving? 18A.
[Mr Irving]
No, not at all. I am saying exactly what happened. What 19his timetable was. 20MR RAMPTON: Mr Irving, the position is this, you quite 21properly in this website entry recognize the possibility, 22I would say the probability, it does not matter, that your 23original thesis, that it was an order from Hitler was 24wrong, do you not? 25A.
[Mr Irving]
Well, you say "probability" and "possibility"; I would say 26what I am saying here is it is important that the learned

. P-47

1public, academics and others who are accessing this 2website realize there are documents which indicate a 3discrepancies in The Times. However, we should not lay 4every word on the gold balance, as the Germans say, 5because it is quite possible and indeed highly probable 6that as soon as Himmler arrived at Hitler's headquarters 7he did not go and have a shower or something, he went 8straight in to see the boss, and said "boss I am here, 9what time shall I come past" and the boss said "oh by the 10way Heydrich I will have to tear a strip off you because 11of what is happening at the Eastern Front". 12Q.
[Mr Rampton]
Mr Irving, who reads these books of yours? Do not take 13that as a suggestion that nobody does, at all, I do not 14mean that, but who are they aimed at? 15A.
[Mr Irving]
How would I know. 16Q.
[Mr Rampton]
Who do you write your books for? When are you writing a 17book, if I write something to my wife I do not use the 18kind of pompous language I use in court, I hope. So you 19know, you have an audience? 20A.
[Mr Irving]
Obviously, I am trying to write for as wide an audience as 21possible so that it is both learned enough for the 22academics to use as a source book, in the case of the 23Goebbels biography but also entertaining enough for the 24general public to look at and read from end to end without 25putting it down at the end of a chapter. 26Q.
[Mr Rampton]
Exactly. It is meant to be readable and it is also

. P-48

1scholarly and authoritative, is it not? 2A.
[Mr Irving]
Yes. 3Q.
[Mr Rampton]
All three of those things. Do you not think, Mr Irving, 4that the respectable approach to this problem of the 5Himmler telephone call, for problem it is, historically? 6A.
[Mr Irving]
Yes. 7Q.
[Mr Rampton]
Would have been to put both possible "theories", as you 8call them, in this website into your book? 9A.
[Mr Irving]
Well, here you have another time discrepancy, Mr Rampton, 10because the book was delivered to the publishers in 1995, 11and this Moscow diary came to my hands in 1998, three 12years, so it would have been quite a feat of imagination 13to imagine what was in the archives and I had not at that 14time seen. 15Q.
[Mr Rampton]
No, but you had assumed without more, had you not? 16A.
[Mr Irving]
This is not the point you were just trying to make, you 17were trying to imply I concealed what I knew, which would 18fall within the grounds of manipulation and 19mistranslation. 20Q.
[Mr Rampton]
What I put to you is this, that you inserted an order from 21Hitler without evidence? 22A.
[Mr Irving]
I inferred an order from Hitler with very strong evidence. 23Q.
[Mr Rampton]
You state it as a categorical fact? 24A.
[Mr Irving]
In my introduction to the book, yes, I draw conclusions. 25Q.
[Mr Rampton]
And also in the text, if I may say so. 26A.
[Mr Irving]
No, in the text I state exactly what the documents say.

. P-49

1Q.
[Mr Rampton]
And you mistranscribe the word Judentransport so as to 2make Hitler appear the more merciful because that is what 3it is about? 4A.
[Mr Irving]
No, I applied the wider interpretation of the "transport" 5rather than the narrow interpretation, which one could 6subsequently apply once one knew more about the history of 7that particular train load. 8Q.
[Mr Rampton]
You do not agree now that you have been caught out by the 9full entry in the Hitler log? 10A.
[Mr Irving]
Mr Rampton, historians are constantly being caught out by 11fresh documents that come into their purview and one is -- 12I am personally very satisfied how infrequently I am 13caught out. I the entire Goebbels biography initially, 14for example, without access to the diaries in Moscow. 15I was pleased to find out how much I managed to work out 16correctly from secondary sources. So it is with 17particular episode, the decodes only came into our 18possession within the last four or five years and yet they 19confirmed exactly what I inferred 20 years, 25 years ago. 20I do not think it is a question of being caught out. If 21one revises and updates information it is not because one 22has been caught out, with all pejorative implications. 23Q.
[Mr Rampton]
I am afraid they are pejorative. I would like to know why 24you say that the decodes (we will go it now, I will come 25back to where I was in a moment) why the decodes confirm 26your account?

. P-50

1A.
[Mr Irving]
I think I have gone through the little bundle this morning 2in some detail, I am glad I did. 3Q.
[Mr Rampton]
You show me the decode, I suppose mean the one on page 17? 4A.
[Mr Irving]
December 1st. 5MR JUSTICE GRAY: Mr Rampton, you are moving to a slightly 6different topic, may I ask one more question? 7MR RAMPTON: Yes. 8MR JUSTICE GRAY: It is back to your website, looking at it 9now, forget what you have written in the past, but looking 10at it now, it is obvious that there was some sort of 11discussion or meeting between Himmler and the journalists; 12is that not right? 13A.
[Mr Irving]
My Lord, I regard this meeting between Himmler and the 14journalist as being a matter of very low priority, I just 15put it in purely because it shows what he was doing that 16morning. It never occurred to me that Gunther d'Alquen 17who is in fact still alive, I believe -- no, he died three 18or four months ago in fact, that he would brought to 19Himmler any kind of serious information about was going 20on. I have never heard that implied or inferred. 21D'Alquen has been questioned on very many occasions, both 22by the courts and by journalists, and I am sure that that 23kind of information would have come into my possession, if 24it had had I would have immediately used it. 25Q.
[Mr Justice Gray]
The entry does suggest that this journalist did have some 26news to give to Himmler, does it not?

. P-51

1A.
[Mr Irving]
I shall go straight home and change the wording of the 2entry, my Lord, because was that not what I intended as 3the author of this passage. 4Q.
[Mr Justice Gray]
What is Reisebericht? 5A.
[Mr Irving]
It is a travel report. He has been travelling around, 6presumably on the Eastern Front and he comes back to 7Himmler. He reports back to Himmler, tells him what he 8has seen, when he visited the SS police divisions and 9whatever -- 10Q.
[Mr Justice Gray]
How would you translate Totenkopfdivision? 11A.
[Mr Irving]
-- Death's Head Division, which is a division on the 12Eastern Front which was not connected, as I understand it, 13with the killing operations, it was actually operating on 14the Eastern Front. I am prepared to be corrected on this 15but I believe that the Death's Head Division was one of 16the elite SS divisions which was fighting on the Eastern 17Front at Moscow at this time of course in severe 18difficulties. 19Q.
[Mr Justice Gray]
Yes, thank you very much. I am sorry, Mr Rampton. 20MR RAMPTON: It is of no matter, my Lord. 21THE WITNESS: I would be very willing to write material in 22between the lines here if I thought it assisted the 23evidence that on this particular case, on the balance of 24probabilities beyond putting the name in, that is all one 25can safely do. But your Lordship will notice that I do 26not hesitate to publicise information which is possibly

. P-52

1hostile to my own interests. 2MR JUSTICE GRAY: I see that. 3MR RAMPTON: The original of I imagine the two documents that 4you are talking about when you are talking about the -- is 5on page 20 of your little bundle; do you have the little 6bundle there? 7A.
[Mr Irving]
Yes. 8Q.
[Mr Rampton]
Items 24 and 25; is that right? 9A.
[Mr Irving]
24 and? 10Q.
[Mr Rampton]
25, items 24 and 25 on page 20? 11A.
[Mr Irving]
Is this April 20th, you are talking about? 12Q.
[Mr Rampton]
No, I am sorry, this is the summons to Jeckeln? 13A.
[Mr Irving]
Would you give me the page number. 14Q.
[Mr Rampton]
Page 20. 15A.
[Mr Irving]
Yes. 16Q.
[Mr Rampton]
Items 24 and 25. 17A.
[Mr Irving]
I see, this is actual the intercepts. 18Q.
[Mr Rampton]
Yes, we go back to page 17 for the English. 19A.
[Mr Irving]
Yes. 20Q.
[Mr Rampton]
It is quite clear, is it not, I mean I agree with you, 21that Himmler was very cross with Jeckeln for what had 22happened? 23A.
[Mr Irving]
For overstepping the guidelines. 24Q.
[Mr Rampton]
Sure. We do not know what guidelines are you tell us? 25A.
[Mr Irving]
I do not know what the guidelines are, no. 26Q.
[Mr Rampton]
It is common ground for once between you and me and the

. P-53

1people who inform me, teach me, educate me, that following 2that incident because no doubt the meeting took place 3between Himmler and Jeckeln on 4th December 1941, yes? 4A.
[Mr Irving]
Yes. 5Q.
[Mr Rampton]
Probably following receipt of the telegram or whatever it 6was on the 1st December. 7A.
[Mr Irving]
Mr Rampton, may I remind you of the very lengthy Bruns 8Report I read out. 9Q.
[Mr Rampton]
I am coming to that. 10A.
[Mr Irving]
Can I answer. 11Q.
[Mr Rampton]
Certainly remind me of that if you wish, yes. 12A.
[Mr Irving]
Yes. In which there is talk in the Bruns Report of Bruns 13saying we sent an urgent message to Hitler's Headquarters, 14how could we do it, then the word comes back to the Riga 15front to the young SS man, he said, we received orders, 16this kind of thing has to stop. This is the kind of 17extraneous information one takes on board when one draws 18inferences from documents. 19Q.
[Mr Rampton]
Mr Irving, I think sometimes you set traps for yourself. 20A.
[Mr Irving]
I try not to. 21Q.
[Mr Rampton]
Actually what Bruns said was mass shootings on this scale 22have got to stop, this has to be done more discreetly? 23A.
[Mr Irving]
Yes. 24Q.
[Mr Rampton]
That is quite different? 25A.
[Mr Irving]
That is what the local SS officers said to him. 26Q.
[Mr Rampton]
It is quite different, is it not, it is not the same thing

. P-54

1at all? 2A.
[Mr Irving]
They wanted to carry on, yes, they wanted to carry. 3Q.
[Mr Rampton]
No, no, Bruns's report of the order through the mouth of 4Altemeyer was that the order which had come from Berlin 5was that mass shootings of this kind on the scale have to 6stop, that has to be done more discreetly? 7A.
[Mr Irving]
This is Bruns' version four years later of what the 22 8year old SS officer who wanted to carry on killing Jews 9told him. He said, we have gone been told by East Prussia 10we have to stop, however, the way he phrased it was, they 11have to stop on this scale and we are going to carry on 12doing it in a more discreet way because that is what they 13wanted to do. But of course they did not, they did not 14carry on, they stopped, as that footnote shows. 15Q.
[Mr Rampton]
We will come to it in a moment. They did stop for a 16time. They stopped doing what Himmler did not like that 17Jeckeln had done which was mass, if you like, semi public 18shootings of people as they go off the trains? 19A.
[Mr Irving]
The footnote which I printed at the end of bundle says 20"the killing of German Jews stopped for several months 21after this exchange". 22Q.
[Mr Rampton]
Yes, that is common ground between you and me, the killing 23of German Jews by this method. Maybe it stopped -- 24A.
[Mr Irving]
Mr Rampton, you are putting words in which do not exist -- 25Q.
[Mr Rampton]
-- we are coming to your use, I add, your use of the Bruns 26evidence in a moment, but before we do that, I want you to

. P-55

1look at these two messages, these two intercepts. There 2is no evidence in that of any intervention or 3participation by Hitler, is there? 4A.
[Mr Irving]
-- no. 5Q.
[Mr Rampton]
It is all between Himmler and Jeckeln? 6A.
[Mr Irving]
Yes. 7Q.
[Mr Rampton]
If you look at the log for the 1st December 1941, I have 8given you the composite version, having lost -- 9A.
[Mr Irving]
Composite version, yes. This is a composite because it is 10made up from three or four different sources by the 11editors. 12Q.
[Mr Rampton]
-- by "composite" I meant composed from different pages in 13the book. 14A.
[Mr Irving]
Yes, December 1st. 15Q.
[Mr Rampton]
December 1st. We see when he is making a telephone call 16he puts "T" is that the editors or is that Himmler? 17A.
[Mr Irving]
That is the editors who put that. 18Q.
[Mr Rampton]
That is the editors. At quarter past one on the 1st there 19is an entry, it must be a telephone call because Heydrich 20is in Prag? 21A.
[Mr Irving]
It is in my bundle two. 22Q.
[Mr Rampton]
The German for Prague is P-R-A-G I take it; is that right? 23A.
[Mr Irving]
Yes. 24Q.
[Mr Rampton]
At quarter past 1 he rings SS Obergruppenfuhrer Heydrich 25in Prag? 26A.
[Mr Irving]
If I may interrupt, we do not know he rang Heydrich, all

. P-56

1we can say is there was a conversation. 2Q.
[Mr Rampton]
Heydrich might have rung him, of course? 3A.
[Mr Irving]
Yes. 4Q.
[Mr Rampton]
The first word is scribedamen; is that secretaries? 5A.
[Mr Irving]
That is correct. 6Q.
[Mr Rampton]
They have a talk about secretaries, it seems, then they 7talk about the executions in Riga? 8A.
[Mr Irving]
Yes. 9Q.
[Mr Rampton]
Is there any inconsistency in that entry and the 10suggestion that what they actually talked about was the 11fact that Jeckeln had not followed the guidelines because 12he was doing it too publicly? 13A.
[Mr Irving]
That is perfectly consistent. I might add this is the 14document 24 in -- I am sorry, document No. 14 in my 15bundle, the original. 16Q.
[Mr Rampton]
Yes. You see there is no evidence in that that that phone 17call to Heydrich, or from Heydrich, is in any way involved 18or prompted by Hitler, is there? 19A.
[Mr Irving]
No, none at all, but you are setting a trap for yourself 20I am afraid. 21Q.
[Mr Rampton]
Why? 22A.
[Mr Irving]
Because if I may refer back to the second of the messages, 23page 17 in my bundle, one in which Himmler contacts 24Jeckeln on December 1st and reads the riot act to him. 25Q.
[Mr Rampton]
Yes, we looked at that. 26A.
[Mr Irving]
It says: "The Jews being outplaced to the Ostland are to

. P-57

1be dealt with only in accordance with the guidelines laid 2down by myself and/or by the Reichssicherheitshauptamt on 3my orders." No mention of Hitler here. 4Q.
[Mr Rampton]
No. 5A.
[Mr Irving]
So this is vitally important to me. I rely on that to 6prove that Hitler was not involved in this order. The 7ordering procedure was not Hitler's. The guidelines were 8not Hitler's. 9Q.
[Mr Rampton]
Mr Irving, one would not expect, given the way in which 10Hitler's so-called orders and, they are very rarely 11orders, they are more often just an airy speech at some 12dinner table, the words "Hitler's orders" in quotes, were, 13as it were, dispersed down the hierarchical column of the 14Nazis, you would not expect Hitler to issue precise 15guidelines about how the Jews were to be treated on 16arrival or how they were to be killed, would you? 17A.
[Mr Irving]
This is your, evidence you are leading or a question? 18Q.
[Mr Rampton]
I am putting it to you that that is right, is it not? 19A.
[Mr Irving]
I rely only on my interpretation of this document that 20Himmler in a secret message says, they are my order and my 21guidelines and you have contravened them. When the 22temptation would surely have been to say you have 23contravened the Fuhrer's orders and the Fuhrer's 24guidelines, which is a very strong point I would make 25because this is the centre point of my own contention. 26Q.
[Mr Rampton]
Do you not think that in light of Bruns's evidence the

. P-58

1guidelines were whatever you do you must make sure it does 2not come to public attention because public opinion in 3Germany will not stand for it if it does, and that that is 4precisely what was discussed between Himmler and the 5journalist on the train or wherever it was on the 30th 6November? 7A.
[Mr Irving]
I think that public opinion in Germany would have stood 8from it from what I know of the Germans -- most Germans 9would not have batted a eyelash at the knowledge that 10these mass killings of the Jews were going on. 11MR JUSTICE GRAY: Well, they were German Jews, I think you 12agreed earlier on? 13A.
[Mr Irving]
German Jews. 14MR RAMPTON: They were Berlin Jews. 15A.
[Mr Irving]
Yes, there was certainly nothing that would have caused 16the Germans problems on the scale that the euthanasia 17killings were causing in public morale problems. Maybe my 18interpretation of the morale in Germany is wrong, you will 19lead evidence later on to contradict me. 20Q.
[Mr Rampton]
I think that probably is right. 21MR JUSTICE GRAY: I am not sure I follow the logic of that, the 22euthanasia programme did cause unrest to use a neutral 23term? 24A.
[Mr Irving]
It caused so much unrest, my Lord, that Hitler had to 25intervene and stop it. 26Q.
[Mr Rampton]
Would not the shooting of large numbers of, to put it

. P-59

1bluntly, healthy Jews, have caused even more unrest, or at 2any rate as much unrest? 3A.
[Mr Irving]
They are very -- they are parallel programmes and in very 4many senses. A lot of the killing operations were 5conducted by the same organizations and the same experts, 6but the campaign of Dr Goebbels against the Jews, 7propaganda campaign had, been conducted with very much 8more vehemence and personal commitment by Dr Goebbels and 9it had converted a large element of the German, population 10in my opinion, to anti-Semitism of a vicious and poisonous 11degree. Whereas his attempt to achieve the same results 12against the crippled and disabled had been limited just to 13one or two films and articles. There a film called "Ich 14Klagean", which was a film about the -- it was a film in 15which the mentally disabled and crippled were portrayed in 16a repulsive manner so the public would accustom themselves 17to idea of putting them out of the way, and this kind of 18propaganda totally failed with the German public. The 19doctors went along with it but the general public when 20they found out about it resisted very strongly euthanasia 21killings. Whereas the Jews were considered to be, 22I think, in Germany fair game as a result largely of 23Dr Goebbels' propaganda. 24Q.
[Mr Rampton]
How good is your facility with Heinrich Himmler's spidery 25Gothic handwriting? 26A.
[Mr Irving]
The handwriting on these pages is not only Himmler, it is

. P-60

1also his Adjutant who still alive in Munich. 2Q.
[Mr Rampton]
Never mind. Let us be precise then and put impersonally, 3with the spidery handwriting, Gothic handwriting on these 4pages? 5A.
[Mr Irving]
On these pages, I will have a shot at it, Mr Rampton. 6Q.
[Mr Rampton]
No, I just wonder how used you are to looking at it. 7A.
[Mr Irving]
Not recently, but over the last few nights I have had to 8strain my eyes once again, thanks to your imputations. 9Q.
[Mr Rampton]
When did you first see these pages which, apparently, you 10did not see the whole of the page for 30th November 1941 11until 17th May 1998, is that right? 12A.
[Mr Irving]
He maintained three separate continuous records. He kept 13the pocket diary. Those pocket diaries are scattered 14around the world. Some are in Israel now, some are in 15Russia. I found two in the United States and gave them to 16the German government. 17 He also maintained a telephone log which was a 18sheet of paper on his disk, like the ones in front of us, 19on which he would write down on one side the name of the 20person he was talking to and on other side what they were 21talking about. Either he or his adjutant would also keep 22a daily agenda of whom he was to see and when and what 23they would talk about or what they had talked about. 24 The fourth series of documents by Himmler you 25will also run into is when he went to see Hitler, he would 26write down on a sheet of paper his discussion points.

. P-61

1Q.
[Mr Rampton]
We are coming to one of those later on today, Mr Irving. 2Can you turn to page 12? 3A.
[Mr Irving]
I should also explain that these are on microfilm 4originally in the United States which is the way I used 5them and accessed them originally in the 1970s. 6Q.
[Mr Rampton]
I wan to be clear what it was you had seen when you wrote 7your books. Can you turn to page 12 in your little 8bundle? 9A.
[Mr Irving]
Right. This is the telephone conversations of November 1030th. 11Q.
[Mr Rampton]
Bear with me, if you do not mind, just allow me to ask 12some questions. What is this a page a copy of? Page 12? 13A.
[Mr Irving]
I just stated that he would have on his desk a sheet of 14paper on which he would either type or insert in 15handwriting the words "telephon gesprach" which is 16T-E-L-E-P-H-O-N G-E-S-P-R-A-C-H. 17Q.
[Mr Rampton]
So that is his what we can ---- 18A.
[Mr Irving]
This is his telephone log. 19Q.
[Mr Rampton]
What we could perhaps imprecisely call his telephone log? 20A.
[Mr Irving]
Yes. 21Q.
[Mr Rampton]
Would you turn over then to ---- 22A.
[Mr Irving]
I was the first person to find and make use of these. 23Q.
[Mr Rampton]
That is as may be. 24A.
[Mr Irving]
Well, it is important. 25Q.
[Mr Rampton]
On page 14? 26A.
[Mr Irving]
Page 14, yes.

. P-62

1Q.
[Mr Rampton]
I ask the same question: is that the same document? It 2looks different. 3A.
[Mr Irving]
It looks different because that is a photocopy from my 4blue volume of these which is on the desk at the other end 5of your bench. 6Q.
[Mr Rampton]
I see. 7A.
[Mr Irving]
Whereas the page previously, when I used it as a facsimile 8in my book "Hitler's War", I had it rephotographed by the 9German Government from the original in their archives as a 10photograph rather than as a photocopy. 11Q.
[Mr Rampton]
So, looking at page 14, somebody has typed "telephon 12gesprach Reichsfuhrer SS" from 1st December 1941? 13A.
[Mr Irving]
Yes. 14Q.
[Mr Rampton]
Who typed that? 15A.
[Mr Irving]
That was typed by his adjutant. A blank sheet of paper 16would be typed for him and laid before him with that 17heading already prepared. 18Q.
[Mr Rampton]
But the other one, the earlier one, has not got that? 19A.
[Mr Irving]
He did not have it, no. That is taken straight off the 20microfilm. I can show that to you on the bound volume. 21Q.
[Mr Rampton]
I follow that. Let us understand it. The second one is 22the thing that he probably keeps in his office? 23A.
[Mr Irving]
I do not think so. He would sometimes use a presheet -- 24pretyped sheet that his adjutant had typed and sometimes 25he would just a take a blank sheet of paper if he was in a 26hurry and write the headings himself.

. P-63

1Q.
[Mr Rampton]
Which may be something of the character of the first one. 2A.
[Mr Irving]
That is correct. They are all in the same file, those 3ones. 4Q.
[Mr Rampton]
What I want to know is what you had when you wrote your 5books. Was it this these two sheets of paper? 6A.
[Mr Irving]
I had those two sheets. 7Q.
[Mr Rampton]
You did not have the fuller version which we can now 8compose? 9A.
[Mr Irving]
It is not a question of the fuller version. The other 10page that you are referring to was not his telephone log, 11but his daily agenda, his appointment book, which is in 12Moscow and which only became available in 1998. 13Q.
[Mr Rampton]
We really would get on quicker if you would let me finish 14the question. I said the fuller version which we can now 15compose from different sources. As the editors of the 16Witte book have done, they have used a number of different 17sources to make a diary for the day. 18A.
[Mr Irving]
Well, they have. They have constructed an artificial 19diary, yes, a calendar. 20Q.
[Mr Rampton]
Exactly, but in the days when you were writing your books, 21the books which we are talking about, this is all you had, 22was it? 23A.
[Mr Irving]
Yes. The Witte book, which is the one to the left of your 24box ---- 25Q.
[Mr Rampton]
That is new, that one? 26A.
[Mr Irving]
Yes. It costs about £70 -- not as much as law books, of

. P-64

1course, but still quite expensive. 2Q.
[Mr Rampton]
I did not buy it. 3A.
[Mr Irving]
It was only published last year. I only obtained it about 4four months ago. 5Q.
[Mr Rampton]
Well, now this is not in any sense a trick or an 6examination question or anything. Can you look at page 712? 8A.
[Mr Irving]
Yes. 9Q.
[Mr Rampton]
And the last entry which I think is probably quarter past 106 -- it might be anyway, might it not? 11A.
[Mr Irving]
The last line or the last entry? 12Q.
[Mr Rampton]
No, the last entry. 13A.
[Mr Irving]
6.15. 14Q.
[Mr Rampton]
It looks like it, does it not? Then across the line? 15A.
[Mr Irving]
"SS Gruppenfuhrer ... Berlin". 16Q.
[Mr Rampton]
What is the first word of the entry in the right-hand 17column? 18A.
[Mr Irving]
"Transport Nachersatz". 19Q.
[Mr Rampton]
It is the "a" of transport which I ask you to look at. 20A.
[Mr Irving]
Yes, that is the real problem. 21Q.
[Mr Rampton]
No, it is not. 22A.
[Mr Irving]
It is because the "a" looks exactly like the "e" in Gothic 23handwriting. 24Q.
[Mr Rampton]
Exactly. In fact, you might think to an English eye it 25looks like a "u"? 26A.
[Mr Irving]
No.

. P-65

1Q.
[Mr Rampton]
"Trunsport"? 2A.
[Mr Irving]
I will explain why it does not. 3Q.
[Mr Rampton]
No, no. 4A.
[Mr Irving]
Well, no, please. 5Q.
[Mr Rampton]
It might be thought to an English person -- just bear with 6me, answer my person -- it might be thought to look like a 7"u", might it not? 8A.
[Mr Irving]
Yes. My Lord, do you have the facsimile in front of you? 9MR JUSTICE GRAY: Yes. I am following. 10MR RAMPTON: Now could you turn to page 14, please? 11A.
[Mr Irving]
14, yes. 12Q.
[Mr Rampton]
In fact, that thing that looks like a "u" to an English 13person in "transport" is an "a", is it not? 14A.
[Mr Irving]
Yes. 15Q.
[Mr Rampton]
Now look at the word which you say you mistranscribed as 16"Juden" which is three lines up from the bottom of the 17right-hand column ---- 18A.
[Mr Irving]
Yes. 19Q.
[Mr Rampton]
--- on page 14. 20A.
[Mr Irving]
Yes, I have it. 21Q.
[Mr Rampton]
It is plainly "haben"; it is the same thing, it is an "a", 22is it not? 23A.
[Mr Irving]
That is what we call Monday morning quarter back ring. It 24is somebody who knows what the answer is. If I had given 25this page to you, say, six months ago, Mr Rampton, and 26said, "Would you mind reading that word?"

. P-66

1Q.
[Mr Rampton]
I would not have had a clue. I cannot read hardly any of 2it. 3A.
[Mr Irving]
That was the position I was in 34 years ago when I looked 4at this. 5Q.
[Mr Rampton]
Why? But you have never gone back to it? 6A.
[Mr Irving]
I must have gone back to it in the 1970s because I retyped 7it on my transcript. 8Q.
[Mr Rampton]
The third letter, you think that is a "d" or you thought 9it was a "d"? 10A.
[Mr Irving]
If you look at the word "Juden" which I would ask you to 11look at variously, for example ---- 12Q.
[Mr Rampton]
We will look at it on page 12, if you want? 13A.
[Mr Irving]
Yes. About eight lines from the bottom. In the third 14line of that entry you have "Judentransport", admittedly, 15it is a bit ---- 16Q.
[Mr Rampton]
It is obscured? 17A.
[Mr Irving]
--- obscured by the word above it. 18Q.
[Mr Rampton]
I agree. 19A.
[Mr Irving]
But you can already begin to see that there are distinct 20similarities in the outline. 21Q.
[Mr Rampton]
I am afraid I cannot accept that. Anyway, the point is 22this, is it not ---- 23A.
[Mr Irving]
Yes, you hasten on, yes. 24Q.
[Mr Rampton]
-- you say, you tell us, that you read that word, that 25entry as reading: "Verwaltungsfuhrer der SS Juden zu 26bleiben"?

. P-67

1A.
[Mr Irving]
Yes, and I can produce my contemporary index card on which 2I made that transcription which shows at that time as 3"Juden zu bleiben". 4Q.
[Mr Rampton]
Turn, please, to page 13 of this bundle and there you have 5it correctly? 6A.
[Mr Irving]
I have corrected it, yes. 7Q.
[Mr Rampton]
You tell us to look at the word "haben". One can see if 8one looks that the letters are squashed? 9A.
[Mr Irving]
It has been typed in subsequently with tippex, yes. 10Q.
[Mr Rampton]
Yes, or whatever was existing then because you say that 11was retyped on a typewriter which you threw away more than 1215 years ago? 13A.
[Mr Irving]
Well, between 10 and 15 years ago -- an old IBM typewriter 14I had. 15Q.
[Mr Rampton]
Yes, but before 1991? 16A.
[Mr Irving]
Yes. 17Q.
[Mr Rampton]
Now can you take "Hitler's War 1991", please? 18MR JUSTICE GRAY: Can I just ask you this, Mr Irving? You are 19fluent in German. If you are trying to write that 20somebody has to stay somewhere, whether it is Jews or 21whoever, you would not say "haben zu bleiben", would you? 22A.
[Mr Irving]
They have to stay, "haben zu bleiben" would be the German. 23Just the same as in English, has to stay, has to remain. 24Q.
[Mr Justice Gray]
Is that right? 25A.
[Mr Irving]
Yes. But, on the other hand, the line "Juden zu bleiben" 26would be also grammatically correct.

. P-68

1Q.
[Mr Justice Gray]
That is abbreviation, but if you are using a verb at all, 2you would say "haben" would be appropriate? 3A.
[Mr Irving]
Yes, and you could equally well say the word above it 4which is "Verwaltungsfuhrer" was a line by itself and a 5topic by itself which is what I assumed it was in the 6original transcript. 7MR RAMPTON: Can you turn now to Hitler's War on page 427, 1991 8edition? 9A.
[Mr Irving]
I do not have it in front of me, but if you would just 10read out the passage. 11Q.
[Mr Rampton]
D1(v). I do not have to read very much. My Lord, page 12427. 13MR JUSTICE GRAY: Thank you. 14MR RAMPTON: At the end of the last complete paragraph on page 15427 -- is that 1991 you have there? 16A.
[Mr Irving]
You will not believe this, but I am only person who does 17not have a copy of that book. People visit my house and 18they think, "Well, that is nice". It has gone! 19Q.
[Mr Rampton]
1991, volume 2, it is D1(v). 20A.
[Mr Irving]
I would be quite ready to concede what you are about to 21say. We do not really need to go into this. 22MR JUSTICE GRAY: I probably ought to know what you are about 23to concede. 24MR RAMPTON: Yes. I do not think we should communicate by 25telepathy, Mr Irving! 26A.
[Mr Irving]
Very well.

. P-69

1Q.
[Mr Rampton]
Now, we have read the first part of this earlier this 2morning about "Hitler being obliged to telephone from 3Hitler's bunker to Heydrich the explicit order that these 4Jews were 'not to be liquidated'". Then you go on after 5the semi-colon ---- 6A.
[Mr Irving]
Can you tell me what page you are on? 7Q.
[Mr Rampton]
I am sorry, 427. I beg your pardon. 8A.
[Mr Irving]
Yes. 9Q.
[Mr Rampton]
"... and the next day Himmler telephoned SS Oswohl Pohl, 10overall chief of the concentration camp system, with the 11order 'Jews are to stay where they are'." When that was 12published, you knew it was wrong, did you not? 13A.
[Mr Irving]
Published what. 14Q.
[Mr Rampton]
When that was published, you knew it was wrong? 15A.
[Mr Irving]
No. 16Q.
[Mr Rampton]
Why not? 17A.
[Mr Irving]
When it was published, yes. You must appreciate this text 18you are looking at here was set by the Americans, by the 19American publisher, A1 Books Limited, in probably 1985 or 201986. They published it round about that time, and two or 21three years later, round about 1990, we approached the 22English publishers and had this American edition 23photographed and what is called offset, and reprinted in 24our own edition which Mr Bateman is holding there, what 25you call the 1991 edition. 26So there is very little connection between the

. P-70

1actual year given as the year of publication and the date 2when text goes into its final cast in stone form. 3Q.
[Mr Rampton]
Tell me that chronology again, Mr Irving. It is rather 4interesting. When was the American edition of this work 5written? 6A.
[Mr Irving]
Written or? 7Q.
[Mr Rampton]
Written. 8A.
[Mr Irving]
I have to piece it together from extraneous information. 9I was in Quay West, I was in Florida. It would have been 101985 and 1986 because I did it before I wrote the Rudolf 11Hess book which was 1987 published, so it was 1985. 12Q.
[Mr Rampton]
So when were the references to the Holocaust removed from 13it? 14A.
[Mr Irving]
The references to the Holocaust? 15Q.
[Mr Rampton]
Yes. 16A.
[Mr Irving]
That is a good question. That is a good question because 17that would, in fact, bring it forward to 1988. 18Q.
[Mr Rampton]
Oh, really? 19A.
[Mr Irving]
Yes. 20Q.
[Mr Rampton]
You see, Mr Irving, let me put my cards on the table, as 21I habitually do, your Holocaust conversion, if I can call 22it that, happened as a result, largely speaking, perhaps, 23of your encounter with Mr Leuchter and his laboratory 24analyses? 25A.
[Mr Irving]
Reading the laboratory reports, yes, which was April 6th 261988.

. P-71

1Q.
[Mr Rampton]
1988? 2A.
[Mr Irving]
Yes. 3Q.
[Mr Rampton]
As a consequence of that, we have been told by you, not in 4this court but elsewhere and you will, no doubt, confirm 5it in due course, this book in that respect ---- 6A.
[Mr Irving]
So the sequence of books is different. I wrote the Rudolf 7Hess book first and then I went to revise this. 8Q.
[Mr Rampton]
If you say so. 9A.
[Mr Irving]
Yes. 10Q.
[Mr Rampton]
It was radically altered in that respect as compared with 11the 1977 edition? 12A.
[Mr Irving]
Taking out the word "Holocaust", yes. 13Q.
[Mr Rampton]
Now, here you have an entry, also as you know accept ---- 14A.
[Mr Irving]
Yes. 15Q.
[Mr Rampton]
--- completely wrong, but it does not ---- 16A.
[Mr Irving]
Yes, but is it not exactly the same wording? 17Q.
[Mr Rampton]
It does not get changed. It is exactly the same wording. 18A.
[Mr Irving]
In other words, I have not actually actively put in 19something; I have just left something to stand. 20Q.
[Mr Rampton]
No, you could have taken it out? 21A.
[Mr Irving]
I could have taken it out, yes. If somebody had come to 22me and had said at the time, "Oh, Mr Irving, by the way, 23do you not remember you misread that word and we have now 24got a better reading", then, believe me, I would have 25taken it out and I would have contacted the Americans and 26changed it. But that is not what happens in real life.

. P-72

1Q.
[Mr Rampton]
You came to believe in 1988 that the so-called Holocaust, 2as you call it, so-called, did not happen? 3A.
[Mr Irving]
I have never used the phrase "so-called Holocaust", 4Mr Rampton. 5Q.
[Mr Rampton]
No, no. I am in the difficulty, as you perfectly well 6understand, Mr Irving, there is no way in the world that 7I am going to concede that it did not happen. That is not 8what this case is about. I call it "so-called" because in 9your eyes by then it was the "so-called Holocaust"? 10A.
[Mr Irving]
You said the "so-called Holocaust, as you call it". 11Q.
[Mr Rampton]
No. As you characterize it? 12A.
[Mr Irving]
Yes. 13Q.
[Mr Rampton]
Yes -- had not happened so you took steps to have the book 14altered for its second edition to remove the references to 15that ---- 16A.
[Mr Irving]
Yes. 17Q.
[Mr Rampton]
--- alleged event? 18A.
[Mr Irving]
Yes. 19Q.
[Mr Rampton]
You did not bother to remove something which was, first of 20all, important and, secondly, completely wrong? 21A.
[Mr Irving]
This is a very subordinate matter in the book. It is a 22piece of secondary information which adds very little to 23the principal argument. The argument turns out now to 24have been correct on the basis of the decodes. This is a 25book of probably half a million words. One word, 26admittedly, I should have changed because I had some years

. P-73

1earlier realized that I had misread it. In all the 2500,000 words it never occurred to me that there may be 3words which I still had not actually changed yet. You are 4absolutely right. 5Q.
[Mr Rampton]
Yes. Then I suggest that your failure to remove it, as 6you could easily have done, it now appears ---- 7A.
[Mr Irving]
Yes. 8Q.
[Mr Rampton]
--- was deliberate because you wanted to keep this picture 9of benign, magnanimous Adolf Hitler holding up his arm to 10save the Jews before the public? 11A.
[Mr Irving]
I do not think so, and I do not think you can suggest that 12just on the basis of that one line. The Jews have to 13remain, have to remain where? Have to remain in 14concentration camps. 15Q.
[Mr Rampton]
Where they are? 16A.
[Mr Irving]
Have to remain in the East, have to remain in the west. 17It is a pretty meaningless sentence as it is. 18Q.
[Mr Rampton]
In that paragraph it is by no means meaningless, is it? 19A.
[Mr Irving]
Yes, but now I would certainly replace it with the decodes 20instead and, in fact, in the latest edition I have. That 21sentence is out and is replaced by absolute diamond 22evidence, the decodes, showing that I am right all the way 23down the line. 24MR JUSTICE GRAY: Am I right in thinking that the entry in the 25log was one of what you have described as the "chain of 26documents"?

. P-74

1A.
[Mr Irving]
This particular one, I never referred to, not the "haben 2zu bleiben". It is totally immaterial and unimportant. 3My Lord, people imagine that books are written in a very 4precise, military kind of way, but they are written in an 5extraordinarily ramshackle way. They go back and forth 6across the Atlantic with all sorts of different people 7setting their hands to them, including lawyers and readers 8and experts and sub-editors and publicity people, and it 9is a miracle that anything finally comes off the end of 10the line. 11MR RAMPTON: Mr Irving, you thought it sufficiently important 12an event, and it is in the context of an order from 13Hitler, according to you, the Jews are to stay where they 14are, it is a coder showing, not only did Hitler say that 15they are not to be killed, not to be liquidated, an 16explicit order, but they are actually to stay where they 17are, they are not to be shunted around from one place to 18another and they are certainly not to be brought to places 19of execution. That is why it is there, is it not? 20A.
[Mr Irving]
No. It is there purely because it was the next entry in 21the Himmler telephone log as I had misread it at the time. 22Q.
[Mr Rampton]
And is sufficiently important in your mind for you to put 23an asterisk footnote, is it not? 24A.
[Mr Irving]
Saying that the facsimile of November 30 telephone 25conversation is reproduced as a facsimile. 26Q.
[Mr Rampton]
I imagine the reason you did not -- I do not know what the

. P-75

1verb is from "facsimile" -- you did not reproduce a 2facsimile of the note of 1st December is that you will say 3that is because it was not sufficiently legible on the 4copy? 5A.
[Mr Irving]
This is what you imagine, is it? Is your imagination what 6you are leading as evidence now? 7Q.
[Mr Rampton]
Yes. I am asking you, what is the reason why -- you had a 8lot of pictures in the second edition, did you not? 9A.
[Mr Irving]
In the 1991 edition? 10Q.
[Mr Rampton]
Yes. 11A.
[Mr Irving]
Yes. 12Q.
[Mr Rampton]
Why did you not put a facsimile of this message in? 13A.
[Mr Irving]
I had something like 3,000 pictures to draw upon, 14Mr Rampton, and it is a judgment call which photographs 15you use. One facsimile of a first line document where an 16order is going out, "the transport of Jews not to be 17liquidated" is for more important than a meaningless 18sentence like "had to remain". 19Q.
[Mr Rampton]
Now, I want to go to, if I may ---- 20A.
[Mr Irving]
But I would like just to round up that argument between us 21by saying that I do not think that you have established 22that I have deliberately manipulated or deliberately 23distorted or deliberately mistranslated anything. It is a 24sin of omission. The sin of omission is that I should 25sometime five years down the road, having realized the 26misreading, it should have occurred to me that one word

. P-76

1had been misinterpreted or misread and that I should take 2that out of the 500,000 other words. 3Q.
[Mr Rampton]
I will be clear about it, Mr Irving, I will lay it out for 4you. You can deny it. It is not my function at this 5stage to persuade his Lordship that I am right. That 6comes later on. You invented a Hitler order. You 7deliberately inflated it into an order to protect the 8whole of the Jews? 9A.
[Mr Irving]
I have not invented a Hitler order, Mr Rampton. I have 10hypothesized the Hitler order in the way that a scientist 11should and I have then supported the hypothesis with 12evidence. 13Q.
[Mr Rampton]
Mr Irving, this is one occasion on which a "yes" or "no" 14will do. You invented it in the sense that you made an 15hypothesis (and I do not say it is an unreasonable 16hypothesis) you made it into a categorical assertion of 17fact. Now, do you agree with that or not? 18A.
[Mr Irving]
Yes, in the introduction. 19Q.
[Mr Rampton]
And do you agree with that as being an irresponsible, 20deliberately deceptive manner for a historian to proceed? 21A.
[Mr Irving]
Quite the contrary on the basis of evidence that I have 22led this morning from my little bundle. 23Q.
[Mr Rampton]
When did you have those Jeckhelm messages? 24A.
[Mr Irving]
The intercepts? 25Q.
[Mr Rampton]
Yes. 26A.
[Mr Irving]
Within the last four weeks I have seen the originals.

. P-77

1Q.
[Mr Rampton]
You did not have them at the time when you wrote this 2book? 3A.
[Mr Irving]
No, but if you have a clean mind when you set out to write 4a book, untrammelled by what you have seen on the TVs and 5on the movies or read in other people's book like that by 6Mr Kershaw, if you start out with a clean mind and you 7read documents that meet your criteria, you are probably 8going to be nudged in the correct path that you arrive at 9the right conclusions. 10Q.
[Mr Rampton]
It may happen, Mr Irving, from time to time in life that 11you tell what you intend to be a lie and subsequent 12events, that wonderful friend hindsight shows that you 13were telling the truth all along. Mr Irving, we are not 14using hindsight. I am concerned with your state of mind 15when you wrote these books. 16A.
[Mr Irving]
You a tell a lie and it turns out to be the truth all 17along? 18MR JUSTICE GRAY: Tell what you intend to be a lie. 19MR RAMPTON: Yes, you tell what you intend to be a lie and it 20turns out to be the truth. 21A.
[Mr Irving]
Why would I intend something to be a lie? 22Q.
[Mr Rampton]
Because you are trying to exonerate, exculpate Adolf 23Hitler. 24A.
[Mr Irving]
Well, this is your opinion, Mr Rampton, and I do not think 25that this can be sustained on the evidence. 26Q.
[Mr Rampton]
No. There are four limbs to this which you can say, "Yes,

. P-78

1it is right" (which you will not) or "No, it is not right" 2(which you will). The second limb to this is that you 3deliberately distorted the original German so as to 4inflate one transport of Jews from Berlin into the whole 5of the German Jews? 6A.
[Mr Irving]
I am not going to respond to that because I have made a 7response to that argument. 8Q.
[Mr Rampton]
Exactly. The third step is that you did not misread by 9accident the word "haben" as "Juden"; you knew all along 10that it was "haben" but you wrote it in as "Jews"? 11A.
[Mr Irving]
I am not going to respond to that because I have stated my 12position very fully on that too. 13Q.
[Mr Rampton]
The fourth proposition is that in any event, on your own 14account, by the time this version of the book, the 1991 15edition, comes out, you know for a certainty, even if you 16did not before, that it was wrong and you deliberately 17chose not to change it? 18A.
[Mr Irving]
On the contrary, you could use the word "deliberate" if 19I put it in at this time. A failure to take something out 20is an omission, a sin of omission, and not a sin of 21commission, if I may put it that way. I respectfully 22suggest that it was a sin of omission and a failure to 23take a word out of 500,000 words is ---- 24Q.
[Mr Rampton]
I do not think it matters what words one uses. 25A.
[Mr Irving]
--- it would be improperly and unjustly described as being 26the kind of distortion that you are trying to impute.

. P-79

1Q.
[Mr Rampton]
Indeed I do. To allow a falsehood once told to remain on 2the record is just as reprehensible as to have invented it 3in the first place, is it not? 4A.
[Mr Irving]
I object to the word "falsehood". 5Q.
[Mr Rampton]
Well, it is a false statement. 6A.
[Mr Irving]
A misreading of a word which is a perfectly legitimate 7misreading of a word which, I suppose, every person in 8this room would have read that way if they had been in 9exactly the same situation. 10Q.
[Mr Rampton]
These books, Mr Irving, are in some sense, are they not, 11history books? 12A.
[Mr Irving]
Which books? 13Q.
[Mr Rampton]
These, the Hitler's War books? 14A.
[Mr Irving]
They are ---- 15Q.
[Mr Rampton]
They are meant to be? 16A.
[Mr Irving]
--- works of history, yes. 17Q.
[Mr Rampton]
--- meant to be history books. They are meant to be a 18history of the Second World War seen not through Hitler's 19eyes, I do not mean that, but with an angle on it that 20perhaps others have not treated before, that is to say, 21the Hitler angle. Hitler is at the centre of these books, 22is he not? 23A.
[Mr Irving]
Yes. 24Q.
[Mr Rampton]
You use what in the second edition it appears by the time 25it appears you know to be a false statement of fact about 26history?

. P-80

1A.
[Mr Irving]
By the time the second edition appears, it is true that 2five years earlier I had known that a word had been 3wrongly read. If you know -- when one publishes 4successive editions of the book, if one is in the 5fortunate position that I am, you are in the position that 6you can, if you have the chance, constantly upgrade and 7update and polish and refine. The latest edition that we 8put out, before it goes to the printers, I have had it on 9the Internet for the last six weeks, and I have invited 10people around the world to spot errors precisely like 11that, and I have increased the reward to a present $8 per 12error. I have had to shell out 2 or $3,000 already. I am 13not in the least bit ashamed because one wants to turn out 14a work that is as perfect and as error free as possible; 15but even so, errors go in. There is a very famous case 16where a man did exactly the same and he offered a very 17large reward if anybody could spot a typographical error 18in a book that he had produced, and it turned out that the 19very title on the title page had been -- can I point out, 20Mr Rampton, another very serious error? 21Q.
[Mr Rampton]
I am listening; it is just that I have to get ready for my 22next question. Do continue, yes. 23A.
[Mr Irving]
I will continue rambling on. There is a very serious 24error in the book "Hitler's War" which is before you, the 251991 edition, and this is that my name does not appear on 26it. That you would consider is a most serious error that

. P-81

1an author can face, that his name does not appear on his 2own book. 3Q.
[Mr Rampton]
It depends, rather, on one's point of view, Mr Irving, 4I would have said. Mr Irving, can we turn please to -- 5what is that? That seems to have your name on it but maybe 6this is the wrong edition. 7A.
[Mr Irving]
Not on the jacket, but actually in the book, Mr Rampton, 8you will not find it. 9Q.
[Mr Rampton]
I have not, I confess, looked, nor do I think I ---- 10A.
[Mr Irving]
I mean, I confess that I am the author for the purposes of 11this action. 12Q.
[Mr Rampton]
Nor do I think that I will spend the court's time doing it 13now. Thank you very much. Mr Irving, I want to return to 14General Bruns. How do you pronounce it, in fact? 15A.
[Mr Irving]
Bruns, B-R-U-N-S. 16Q.
[Mr Rampton]
With no umlaut though? 17A.
[Mr Irving]
No umlaut. 18Q.
[Mr Rampton]
If that is the right word. Do you have your two-page 19English translation? 20A.
[Mr Irving]
I think I know it virtually off by heart. 21Q.
[Mr Rampton]
I would rather you had it. 22A.
[Mr Irving]
It is in my opening statement. I have it, yes, I have the 23opening statement version. 24Q.
[Mr Rampton]
Maybe I should use that. It will make it easier for 25everybody. I have the TRO version. 26A.
[Mr Irving]
It is on page 22. You say that Bruns' account has

. P-82

1verisimilitude? 2A.
[Mr Irving]
Yes. 3Q.
[Mr Rampton]
Account of what he said he saw? 4A.
[Mr Irving]
I marked that because later on under oath in the witness 5box in Nuremberg he said he had not been there, I find 6that hard to believe. 7Q.
[Mr Rampton]
I agree with you, I think it has verisimilitude for what 8it matters. It is an horrendous account of an 9unpleasant -- more than an unpleasant event in human 10history. That is not what I am interested in. Given that 11it has verisimilitude, if you look in the middle of page 1222, one of the things that Bruns was overheard saying to 13whoever he was speaking to was this, middle of the 14page: "I told that fellow Altemeyer?" In fact, Altemeyer, 15whose name I shall always remember and who will be added 16to the list of war criminals, listen to me they [that is 17Jews] represent valuable manpower. Altemeyer: Do you call 18Jews valuable human beings, sir? I [that is Bruns said] 19Listen to me properly, I said valuable manpower, I did not 20mention their value as human beings. He said [Altemeyer 21said] Well, they are to be shot in accordance with 22the Fuhrer's orders! I said: Fuhrer's orders? He said, 23yes, whereupon he showed me his orders." 24Now that has never appeared in any of your 25books, has it? 26A.
[Mr Irving]
Too true, yes, absolutely right.

. P-83

1Q.
[Mr Rampton]
Why not? 2A.
[Mr Irving]
I discounted it. 3Q.
[Mr Rampton]
Why? 4A.
[Mr Irving]
Because I am familiar with other sources where people 5claim to be acting on Hitler's orders because it was the 6ready answer to shut anybody up if somebody came and 7complained then the senior officer or the other officer 8would say: "Do not start criticising me, this is the 9Fuhrer's orders", and I discounted the subsequent sentence 10about "then he showed it to me" for exactly the same 11reason that I discounted the statement at Nuremberg that 12Eichmann claimed that the -- rather Wisliceny claimed that 13Eichmann had showed him the orders. There are no orders. 14They have not been found. We have now been in the 15archives, in and out of the archives of the world for the 16last 50 years, since the end of World War II, 55 years and 17no primary or secondary or tertiary evidence of the 18existence of these orders has been found as regards the 19war years. 20 I concede that in interrogations and in War 21Crimes Trials and elsewhere everyone else is happy to talk 22about Fuhrer's orders but the fact remains had there been 23any such order or any such document, and you are tapping 24this one, this is what I will put in the category of 25"interrogations", had there been any such order, it would 26have surfaced by now.

. P-84

1MR JUSTICE GRAY: You put this in the category of 2"interrogations", did you say? 3A.
[Mr Irving]
It is at the end of war, my Lord, he is in the enemy 4hands. 5Q.
[Mr Justice Gray]
He is being surreptitiously... 6A.
[Mr Irving]
I appreciate that, my Lord, but it is in a grey area. He 7is in the enemy's power and custody and I draw attention 8to the line a bit earlier up where he says: "His name 9I shall always also remember and who will be added to the 10list of war criminals". That is a gentle hint to me that 11perhaps he is not entirely unaware that somebody may be 12listening. 13MR RAMPTON: What do you know -- 14A.
[Mr Irving]
You must appreciate that, my Lord. 15MR RAMPTON: What do you know General Bruns? 16A.
[Mr Irving]
-- what do I know of him? 17Q.
[Mr Rampton]
What do you know of him, yes. 18A.
[Mr Irving]
Only what I know from this document and from the writings 19of Gerald Fleming. I suppose we would describe him now as 20been an anti-Nazi by the time the war ended, but then a 21lot of people were anti-Nazi by the time the war ended. 22Q.
[Mr Rampton]
--- what if they happened to be an anti-Nazi all along, 23there were such people in German during the 1940s, were 24there not. 25A.
[Mr Irving]
Undoubtedly, yes. 26Q.
[Mr Rampton]
Quite a lot of the ordinary army, I am not talking about

. P-85

1the SS, who are not army at all, really, were anti-Nazi? 2A.
[Mr Irving]
Is this the evidence that you are leading, I am not 3familiar with any statistical basis for that. 4Q.
[Mr Rampton]
I am suggesting you could give me the answer "yes"? 5A.
[Mr Irving]
I have not seen any documentary evidence of that. I do 6not think GALLUP Polls are conducted among the Wehrmacht 7soldiers who still support Adolf. I always want to see 8this kind of evidence and if I can just -- if I can just 9add here we have got very high quality evidence of the 10morale and opinions of the Germans. We have the SD 11stinnungsberichge, which were the morale reports where 12Gestapo agents would hang around in bars listening to what 13people said. We have sacks and sacks of captured mail, 14captured by the Allies when a troop ship were caught or 15when positions were overrun. We know exactly what these 16people were writing. So we are very well informed about 17what was going on. I have never seen any kind of 18statistical analysis. 19Q.
[Mr Rampton]
If this is not an interrogation, which it plainly is not? 20A.
[Mr Irving]
Yes. 21Q.
[Mr Rampton]
And if General Bruns does not know that he is being 22recorded, and if it be the case that he simply is chatting 23to his fellow prisoners in German, which he is, am 24I right? 25A.
[Mr Irving]
While you just read that, may I just add a further point, 26we are dealing here with a 22 year old young man called

. P-86

1Altemeyer who has been put in SS uniform. 2Q.
[Mr Rampton]
I am sorry, Mr Irving, there are times when you may make 3speeches and times when you must answer my questions, this 4is one of them; you said yesterday, no, I think this is on 5Day One? 6A.
[Mr Irving]
I will come back to what I was about to say when you have 7finished. 8Q.
[Mr Rampton]
"This document has, in my submission, considerable 9evidentiary values... it is not self-serving, the General 10is not testifying in his own interest, he is merely 11talking, probably in a muffled whisper to fellow prisoners 12at a British interrogation centre and he has no idea that 13in another room British experts are listening to and 14recording every word. We also have the original German 15text of this document. I might add my, Lord ... " 16MR JUSTICE GRAY: That, I think, was Mr Irving's speech. 17MR RAMPTON: That is Mr Irving's speech. That is on page 46 -- 18A.
[Mr Irving]
Can I make it easy for you, Mr Rampton, and say I accept 19Altemeyer did say those words. 20Q.
[Mr Rampton]
-- right. 21A.
[Mr Irving]
Or as best as Bruns recalls them. 22Q.
[Mr Rampton]
The whole of Bruns' account in this regard has the ring of 23truth then? 24A.
[Mr Irving]
Yes. 25Q.
[Mr Rampton]
So it is likely also then, is it, one cannot be certain, 26one was not there.

. P-87

1A.
[Mr Irving]
It is very likely that the SS officer concerned used those 2words. 3Q.
[Mr Rampton]
It is likely also he used the words at the end of this 4extract on the bottom of page 24 of your opening: "Here 5is an order, just issued, prohibiting mass shootings on 6that scale from taking place in future" -- 7A.
[Mr Irving]
Have we now left that previous passage, if so -- 8Q.
[Mr Rampton]
-- I am coming back to it, but I want to try and be 9consistent, if you are saying that we can believe that 10Altemeyer used the words in the first passage, can we also 11believe that Altemeyer said this: "Here is an order, just 12used, prohibiting mass shootings on that scale from taking 13place in future"? 14A.
[Mr Irving]
-- that I believe. 15Q.
[Mr Rampton]
"They are to be carried out more discreetly." 16A.
[Mr Irving]
That I attach less credibility to. 17Q.
[Mr Rampton]
Why? 18A.
[Mr Irving]
It is the kind of throw away line that soldiers would use, 19particularly in captivity, adding a gag, looking for a bit 20of a snigger from someone, saying not to be done on a mass 21shooting, of course, has to be done a bit more 22discreetly. If I can draw a comparison, you very rightly 23read out a passage of a speech I made in Calgary where 24I protested that I had been called a mild fascist by the 25newspapers and I said I do not like that word "mild" it is 26a throw away line, you are looking for a laugh.

. P-88

1Q.
[Mr Rampton]
I do not -- 2A.
[Mr Irving]
You then attach great weight to the fact Mr Irving 3obviously accepts he is fascist, which is untrue. But 4these things happen in conversation, Mr Rampton. It calls 5for judgment and integrity before you use any particular 6part of a sentence. 7Q.
[Mr Rampton]
-- no, you misjudge me, Mr Irving, you should re-read what 8I actually said and you will find what you just said is a 9misrecollection. However, that matters not in the 10slightest. 11A.
[Mr Irving]
Can I now go back to the previous part you are relying on 12in that, where he says "here are the Fuhrer's orders" and 13he showed it to me. 14Q.
[Mr Rampton]
He did not say that. He said "whereupon --" this is 15important, Mr Irving, you must be accurate, this is an 16important distinction: "Whereupon he showed me his 17orders"? 18MR JUSTICE GRAY: That is Bruns speaking, not Bruns quoting 19Altemeyer? 20A.
[Mr Irving]
Altemeyer says, well, they are to be shot in accordance 21with the Fuhrer's orders, Bruns said: Fuhrer's orders? 22Yes, says Altemeyer, whereupon he showed me his orders. 23MR RAMPTON: His orders? 24A.
[Mr Irving]
Yes. 25Q.
[Mr Rampton]
That does not mean the Fuhrer's orders, that means 26Altemeyer's orders?

. P-89

1A.
[Mr Irving]
I am grateful to you for drawing that to my attention. If 2you wish to infer from that that he showed to Bruns orders 3from Hitler, or orders quoting orders from Hitler, because 4he later on talks about the Fuhrer's orders, can I now 5comment on that? 6Q.
[Mr Rampton]
I am not going to comment on a suggestion I have not -- 7I am not going to invite you to comment on a suggestion 8I have not made. 9A.
[Mr Irving]
May I nevertheless comment? 10Q.
[Mr Rampton]
No, Mr Irving, you may not. If his Lordship permits it, 11why, yes. My question is a completely different one; my 12question is this, it is credible that Altemeyer said what 13he is here reported as having said? 14A.
[Mr Irving]
Yes. 15Q.
[Mr Rampton]
It is also credible, is it not, that he showed Bruns a 16written order saying that these people were to be shot? 17A.
[Mr Irving]
Yes. 18Q.
[Mr Rampton]
Good, thank you very much. Put those two things together, 19and there is evidence here which needs to be taken into 20account; do you agree? 21A.
[Mr Irving]
Discounted or taken into account, yes. 22Q.
[Mr Rampton]
Take into account, brought to the attention of the public 23or the historians so that they can make up their own minds 24whether or not this is evidence of a Fuhrer order for 25these shootings? 26A.
[Mr Irving]
You are absolutely right .

. P-90

1Q.
[Mr Rampton]
Thank you. 2A.
[Mr Irving]
Can I continue? 3Q.
[Mr Rampton]
Yes. 4A.
[Mr Irving]
I have done precisely that. 5Q.
[Mr Rampton]
Where? 6A.
[Mr Irving]
On my website. 7Q.
[Mr Rampton]
Yes, but what about your books? 8A.
[Mr Irving]
I am not writing books about the Holocaust, Mr Rampton, 9I am writing books about Adolf Hitler. The book is already 101,000 pages long. If I was to start going into that 11detail then I would be sternly reprimanded by the editors 12saying, Mr Irving, when I wrote the Hermann Goring 13biography, the American publishers came to me and said 14Mr Irving will you please cut out 2,000 lines from the 15printed text. This happens. We do not have a problem 16that our books are too short, we have the problem that our 17books are too long. 18Q.
[Mr Rampton]
Yes. Mr Irving -- 19A.
[Mr Irving]
But the entire document is on the Internet and I am the 20one who placed it there. 21Q.
[Mr Rampton]
-- Mr Irving, you have made reference to this Bruns 22testimony in your published books? 23A.
[Mr Irving]
As I said in my opening speech, again and again, it is the 24most harrowing account and element of the Holocaust. 25Q.
[Mr Rampton]
But without ever mentioning either of these verbal 26exchanges in their entirety?

. P-91

1A.
[Mr Irving]
Absolutely right. 2Q.
[Mr Rampton]
Why not? 3A.
[Mr Irving]
Because this is descending into a level of textual 4analysis which would bore the pant off an audience, which 5would be totally out of place in a book about Adolf Hitler 6for which I am perfectly prepared to discuss here in court 7if you attach importance to you, but you do not want me to 8discuss it. 9Q.
[Mr Rampton]
I am not trying to prove a case about Adolf Hitler one way 10or the other? 11A.
[Mr Irving]
But you will not allow me to discuss it here. 12Q.
[Mr Rampton]
Of course I allow you discuss it here. 13A.
[Mr Irving]
You stopped me. 14Q.
[Mr Rampton]
I interested in why it makes no appearance -- 15A.
[Mr Irving]
Because I have reasons for discounting it. 16MR JUSTICE GRAY: Discounting bits of it I suppose would be 17more accurate. 18A.
[Mr Irving]
-- I am discounting the bit about being shown the Fuhrer's 19order, or being shown orders implicating Hitler. 20MR RAMPTON: Why do you discount it? 21A.
[Mr Irving]
Ah, at last. Because other evidence shows that Hitler had 22not issued the order; firstly I said that nowhere in all 23the documentation of all the world's archives has any such 24order turned up. 25Q.
[Mr Rampton]
That not evidence, that is an absence of evidence? 26A.
[Mr Irving]
It is evidence in a very powerful sense.

. P-92

1Q.
[Mr Rampton]
It is a negative piece of evidence? 2A.
[Mr Irving]
I hate to remind you of the basic principle of English law 3that a man is innocent until proven guilty; am I right? 4Q.
[Mr Rampton]
Hitler is not on trial, alas. 5A.
[Mr Irving]
Is Hitler somehow excluded from this general rule of fair 6play? 7MR JUSTICE GRAY: I think that is a slightly -- 8THE WITNESS: Mr Rampton talks about absence of evidence not 9counting, all the world's archive are effectively now open 10to us, there has not come forward any collateral evidence 11and as for a 22 year-old SS man's word being believed when 12he has the power of life and death over thousands of Jews 13who have just been ordered shot, this SS man obviously has 14more front than Selfridges, he is going around saying, 15yes, we have orders, I have orders, do not come critising 16me, that is what is going on here. That is the way I read 17that and that is the way any responsible historian should 18read it. 19MR JUSTICE GRAY: Let us move on. You accept a lot what is in 20here? 21A.
[Mr Irving]
-- I do indeed. 22Q.
[Mr Justice Gray]
But you do not accept that particular -- 23A.
[Mr Irving]
Certainly not to the degree -- 24Q.
[Mr Justice Gray]
As it was reflecting the reality? 25A.
[Mr Irving]
-- that one general's recollection of what a 22 year old 26SS man told him in Riga should be taken discounting the

. P-93

1negative evidence as Mr Rampton calls it of all the 2world's archives. 3MR RAMPTON: Mr Irving, I am not going to take you up on that; 4you can argue with my experts about that if you like. 5I am interested in the way you write your books. Both in 6the Nuremberg book, and we will not need to look at them, 7because we are looking for a black hole, both in the 8Nuremberg book and in the Goebbels book you mention, 9either in the text or in a footnote, or both, the Bruns, 10call it what you like? 11A.
[Mr Irving]
Yes, I consider my duty to draw everyone's attention to 12this report. 13Q.
[Mr Rampton]
But nowhere in either of those books do you mention either 14of these exchanges that Bruns reported he had with 15Altemeyer? 16A.
[Mr Irving]
You are repeating yourself, I will repeat the answer. 17Q.
[Mr Rampton]
You repeat your answer, yes, please. 18A.
[Mr Irving]
No, I did not. 19Q.
[Mr Rampton]
No, you did not. You actually have done this with the 20Altemeyer passages; may I show you? Can you find, please, 21file D3(i), I think it is tab 27 that I want. I will tell 22you where to look in a moment, Mr Irving, I just want to 23remind you and his Lordship of what Bruns actually said on 24Altemeyer's return with an order from Berlin after the 25shootings had been reported. "Here is an order, just 26issued, prohibiting mass shootings on that scale from

. P-94

1taking place in the future." That is your translation of 2the German. 3A.
[Mr Irving]
Yes. 4Q.
[Mr Rampton]
It is one that I agree with. 5A.
[Mr Irving]
This is from my introduction? 6Q.
[Mr Rampton]
Yes, but then it goes on, does the sentence reported by 7General Bruns: "They are to be carried out more 8discreetly." That is the full text of General Bruns' 9words as a report of what he was told by Altemeyer. Will 10you please look at page 415 of the document which is at 11tab 27 which is a written introduction by you in the 12Journal of Historical Review, to your new edition of 13"Hitler's War". At the end of that article there are 14some footnotes on page 415. 15MR JUSTICE GRAY: Why are we looking at it there as opposed to 16in the copy? 17A.
[Mr Irving]
That is what I am wondering. 18MR RAMPTON: Copy of which book? 19MR JUSTICE GRAY: We have the whole of "Hitler's War". 20MR RAMPTON: It is not in the book. 21MR JUSTICE GRAY: I thought you said it was. 22MR RAMPTON: No. 23MR JUSTICE GRAY: I thought this was the introduction to the 241991 edition. 25MR RAMPTON: Well, I do not think it is. It is an edition 26I have not got, that is why. That is why we have it

. P-95

1separately. 2MR JUSTICE GRAY: I follow. 3THE WITNESS: We also have a date on that, January 1989. 4Q.
[Mr Rampton]
Two dates '76 and '89. 5A.
[Mr Irving]
That answers the point. 6MR JUSTICE GRAY: Two editions. 7MR RAMPTON: Anyhow, if you look at the footnotes in the right 8hand column on page 415, footnote 7 says this: "The most 9spine chilling account of... methodical mass murder of 10these Jews [that is the Berlin Jews] at Riga is 11in ... 1158 in file etc. in the Public Record Office, 12Major General Bruns, an eyewitness, describes it to fellow 13generals in British captivity in April 25th 1945 unaware 14that hidden micro phones are recording every word. Of 15particular significance his qualms about bringing what he 16had seen to the Fuhrer's attention and the latter's [that 17is Hitler's] renewed orders that such mass murders were to 18stop forthwith"? 19A.
[Mr Irving]
Yes. 20Q.
[Mr Rampton]
As an account of what Bruns is recorded as having said 21that is completely dishonest, is it not? 22A.
[Mr Irving]
Does it say that the Bruns account is the only source for 23that final paragraph, that final sentence? 24Q.
[Mr Rampton]
It purports to be an account of what Bruns said, does it 25not, Mr Irving? 26A.
[Mr Irving]
It references the Bruns' file as the source of that

. P-96

1material in the main text, and it adds the comment: "Of 2particular significance his qualms about bringing about 3what he has seen to the Fuhrer's attention and the 4latter's renewed orders that such mass murders were to 5stop forthwith". In other words, that was of particular 6significance. 7Q.
[Mr Rampton]
Of particular significance in the Bruns's eyewitness 8testimony. 9A.
[Mr Irving]
I do not say that. 10MR JUSTICE GRAY: Read it through to yourself again. 11MR RAMPTON: Read it through. 12MR JUSTICE GRAY: And consider that answer, Mr Irving. 13A.
[Mr Irving]
Of the particular significance his qualms about bringing 14what he had seen to the Fuhrer's attention and the 15latter's renewed orders that such mass murders were to 16stop forthwith. I see no objection to that as being an 17encapsulated version of Bruns's report -- may I read out 18from the Bruns' report the sentences on which I would 19rely? 20MR RAMPTON: No, you may not, Mr Irving. I would like you to 21read the whole of that footnote and I shall repeat my 22question, and we will have a "yes" or "no" if you please. 23A.
[Mr Irving]
You will not let me read out these sentences in the Bruns 24report on which I rely? 25MR JUSTICE GRAY: In a moment. Just do what Mr Rampton is 26asking at the moment.

. P-97

1A.
[Mr Irving]
Very well. "The most spine killing account --" 2MR JUSTICE GRAY: No, read it to yourself. 3MR RAMPTON: Yes, I did not mean. 4A.
[Mr Irving]
Well, because I am accused of being a Holocaust denier it 5is interesting that I am repeatedly saying this kind of 6thing, including in journals like this. You do not me 7read it out loud? 8Q.
[Mr Rampton]
I would like you to read it yourself. 9A.
[Mr Irving]
You do not want public to hear what I wrote. 10MR JUSTICE GRAY: It has just been read out. 11A.
[Mr Irving]
Yes, I have read it. 12MR RAMPTON: You have read it. Now I will repeat my question; 13do you not agree that read as a whole, as one most read it 14as a whole, not selecting those little bits which one 15would rather ignore, and you are relying on the ones you 16want to be heard, reading that as whole, do you not agree 17that that is a singularly dishonest account of what Bruns 18was recorded as having said? 19A.
[Mr Irving]
I do not agree. 20Q.
[Mr Rampton]
Why? 21A.
[Mr Irving]
Can I now draw attention to the sentences in the Bruns 22Report on which I rely? 23Q.
[Mr Rampton]
Whatever you wish in answer to my question. 24A.
[Mr Irving]
I will summarize them and you can tell me if it is a false 25summary. They had difficulty, he did not want to write 26the report himself, he persuaded a junior army officer to

. P-98

1go down the road and have a look and come back and write 2up what he had seen. The question then was who is going 3to bring it to the Fuhrer's attention; they work out a way 4to bring to the Fuhrer's attention involving Vice-Admiral 5Canaris, shortly the orders come back, such mass murders 6have to stop. Am I totally wrong in drawing the perfectly 7justified inference that as a result of this army 8officer's report being drawn to the Fuhrer's attention the 9orders come, which we have seen in the intercepts that 10such mass murders have to stop. 11MR JUSTICE GRAY: Mr Irving, can I put it to you straight, as 12it were, because this is the suggestion. 13A.
[Mr Irving]
Yes. 14Q.
[Mr Justice Gray]
That what you have said as being of particular 15significance, namely the renewed orders that such mass 16murders were to stop forthwith, totally perverts the sense 17of Bruns' conversation in captivity because Bruns makes 18clear that Altemeyer said that the killings were to 19continue? 20A.
[Mr Irving]
I think I have explained the reason why I discounted that 21part of his remark, my Lord, this was the... 22Q.
[Mr Justice Gray]
Yes, but are you giving particular significance to a 23proposition which is the opposite of what one finds in the 24document? 25A.
[Mr Irving]
The decision of the little man on the spot in Riga is of 26no significance to the argument that Hitler had given the

. P-99

1order quite clearly that such killings had to stop. 2Q.
[Mr Justice Gray]
Yes. 3A.
[Mr Irving]
Have I made it plain, my Lord. 4Q.
[Mr Justice Gray]
Yes, you have. 5A.
[Mr Irving]
Thank you. I think that -- 6MR RAMPTON: Do you think, Mr Irving, that if General Bruns 7were here today he would think what you have done with 8what he said was fair and honest? 9A.
[Mr Irving]
-- taken in elements, stage by stage, yes. 10Q.
[Mr Rampton]
Do you? I see. You said it again in that same file you 11have got there, I think it is at -- it is at tab 30, this 12is a paper, I think, presented by you at the Institute of 13Historical Review, a talk given by you? 14A.
[Mr Irving]
A talk? 15Q.
[Mr Rampton]
Yes, a talk, in October 1992, and the passage which 16matters is again an account of the Bruns evidence on page 1724, ignore the stamped number at the bottom of page, 24 of 18the article. I think this is an answer to a question very 19likely. Yes, it is. It is in the bottom part of the 20left-hand column on that page' does your Lordship have it? 21MR JUSTICE GRAY: Yes, I have. 22MR RAMPTON: This is the last thing, my Lord, I do before the 23adjournment if that is convenient. 24 "But other reports unfortunately have the ring 25of authenticity. Most of these SS officers, the gangsters 26that carried out the mass shootings were I think acting

. P-100

1from the meanest of motives. There was a particular SS 2officer in Riga who is described in the report by Bruns in 3which Bruns said the difficulty for us was how to decide 4to draw what he had seen what we had seen to the Fuhrer's 5attention, and eventually they sent a lieutenant down the 6road and got him to write what he saw and they sent this 7report signed by the lieutenant up to the Fuhrer's 8headquarters through Canaris. Two days later the order 9comes back from Hitler 'these mass shootings' [in quotes 10notice, Mr Irving] these mass shootings have to stop at 11once so [and this is now you again] Hitler intervened to 12stop it." 13 As a quotation from the evidence of General 14Bruns those words in quotes: "These mass shootings have 15got to stop at once", is a complete perversion, is it not, 16of what Bruns actually said? 17A.
[Mr Irving]
What is the difference? 18Q.
[Mr Rampton]
He said these mass shootings have got to stop at once, 19they have to be done more discreetly? 20A.
[Mr Irving]
The 22 year old SS man allegedly said that to Bruns -- 21Q.
[Mr Rampton]
That is what Bruns is reported as having told his fellow 22officers? 23A.
[Mr Irving]
-- yes. 24Q.
[Mr Rampton]
He did not say this, did he, that you have written here? 25A.
[Mr Irving]
I gave the essential part of the information, which was 26that the orders -- we are talking about here the chain of

. P-101

1command from Hitler downwards and that the killings were 2carried out there, the SS officers on the spot and I make 3this very clear distinction, the gangsters were in the SS 4who did the killings on the Eastern Front and for that 5there is any amount of evidence, a lot of which you have 6in your own files but the evidence of Hitler's involvement 7is very tenuous and goes in the direction which I 8indicated from my small bundle. My I also draw your 9attention to the fact this is a question and answer 10session, Mr Rampton. 11Q.
[Mr Rampton]
Yes, I follow that. 12A.
[Mr Irving]
So there is no script. I am not reading out from a 13document. 14MR JUSTICE GRAY: Yes, I think the point on the quotation marks 15is not a fair one given that this is which you said in a 16speech because whoever transcribed it may well have just 17added the quotation marks? 18A.
[Mr Irving]
Not just but obviously when one is answering questions 19from the floor one is giving an encapsulated version of 20the essence of a document as one recalls it. 21Q.
[Mr Rampton]
I follow that. 22MR RAMPTON: My Lord, there are two minutes, so it might help. 23MR JUSTICE GRAY: Yes, why not use them. 24MR RAMPTON: If might help if we looked at the original German 25of Bruns said that Altemeyer had said. 26A.
[Mr Irving]
It does sometimes vary from the translation.

. P-102

1MR JUSTICE GRAY: Where do we find that? 2MR RAMPTON: It is bundle H1(vii), some of Professor Evans 3documents? 4A.
[Mr Irving]
It is actually from my discovery. 5Q.
[Mr Rampton]
No, I do not know where it comes from. 6A.
[Mr Irving]
If it has a number written on the top right hand corner. 7MR JUSTICE GRAY: Unfortunately, I have not brought that 8particular file. 9THE WITNESS: I was the person who discovered this document. 10MR RAMPTON: The page, have you got that? 11A.
[Mr Irving]
Not in front of me. 12Q.
[Mr Rampton]
You do not have the German? 13A.
[Mr Irving]
No. 14Q.
[Mr Rampton]
It is 233, which looks to me like the British transcript 15it is the transcript of Bruns' actual words -- before 16I ask the question I must look in the dictionary because 17I have not got my own. 18MR JUSTICE GRAY: "Massen" is underlined, is it underlined in 19the translation? 20MR RAMPTON: Yes, I do not know who did that. 21MR JUSTICE GRAY: No, it looks original. 22A.
[Mr Irving]
It is original. 23MR RAMPTON: Shows how important it is, Mr Irving, to go back 24to source, does it not. 25A.
[Mr Irving]
That is a "yes". 26Q.
[Mr Rampton]
Do you know how those transcripts were made? They were

. P-103

1secretly recorded, presumably by some hidden microphone. 2A.
[Mr Irving]
It is still very secret but in the next door room 3everything was taken down outsize large disks like the old 4fashioned 78s. 5Q.
[Mr Rampton]
Now can we assume that this is an accurate transcript; 6there is no reason to doubt it, is there? 7A.
[Mr Irving]
They are normally very accurate transcripts. They had 8research teams who would have extensive catalogues and 9indices to check on words and names. 10Q.
[Mr Rampton]
Let us look at the German, you will help me when my German 11strays off course as it very likely will, the relevant 12passage is at the bottom of page 233. It is line 13beginning der Altemeyer something triumphantly said 14quotes: "Hier ist eine Vorgugung" that is an order? 15A.
[Mr Irving]
Not necessarily, that is a strange kind of order. It is 16more of an ordinance. 17Q.
[Mr Rampton]
Yes. Here is an ordinance come, just come? 18A.
[Mr Irving]
Yes. 19Q.
[Mr Rampton]
That says, yes? 20A.
[Mr Irving]
Yes. 21Q.
[Mr Rampton]
To the effect that, let us say, shall we, dass? 22A.
[Mr Irving]
Yes. 23Q.
[Mr Rampton]
This kind of or these kinds of "derartige"? 24A.
[Mr Irving]
That kind of, yes. 25Q.
[Mr Rampton]
These kind of? 26A.
[Mr Irving]
Mass shootings.

. P-104

1Q.
[Mr Rampton]
Mass shootings, do you hear how I read it, mass shootings? 2A.
[Mr Irving]
Yes. 3Q.
[Mr Rampton]
In future, in Zukunft... which means must not take place 4any more, does it not? 5A.
[Mr Irving]
Yes. 6Q.
[Mr Rampton]
"Das soll vorsichtiger gomacht worden"; that means this 7shall in future be more cautiously or discreetly done? 8Yes? 9A.
[Mr Irving]
Very good, Mr Rampton, yes. 10Q.
[Mr Rampton]
Well, not very good, but it is not very difficult, is it, 11two things about it? 12A.
[Mr Irving]
Yes. 13Q.
[Mr Rampton]
It translates not as "shootings on this scale", it 14translates as "shootings of this kind"? 15A.
[Mr Irving]
Yes. 16Q.
[Mr Rampton]
And the word "mass"? 17A.
[Mr Irving]
Yes. 18Q.
[Mr Rampton]
Is underlined. Do you agree that that is likely to 19reflect the transcriber's impression of the emphasis which 20Bruns placed upon that word when he spoke it? 21A.
[Mr Irving]
Yes. 22Q.
[Mr Rampton]
Good. It is a very significantly different version from 23the one you have, if I may use a colloquialism "been 24punting"? 25A.
[Mr Irving]
You mean by leaving off the corollary? 26Q.
[Mr Rampton]
Yes, it fits in with the last part of the sentence, "it

. P-105

1must be done more discreetly"? 2A.
[Mr Irving]
Yes. 3Q.
[Mr Rampton]
Does it not? 4A.
[Mr Irving]
Yes. 5Q.
[Mr Rampton]
Now why do you reject the second half of that message and 6embrace the first half? 7A.
[Mr Irving]
We have been over this, but we will attack it from a 8different angle. We are dealing not with a verbatim 9transcript of what Altemeyer said, we are dealing with the 10recollection by a German army general four years later of 11what Altemeyer had said. We are dealing with a triumphant 12SS young officer, triumphantly he declaims this. The SS 13were eager to kill Jews. They were very indignant when 14orders had come down from whoever that this killing had to 15stop. They were eager to carry on somehow and so they 16were eager to find some kind of loophole that they allowed 17them to go on bumping off their enemies. So he tells the 18army officer, well, we have the orders but we are going to 19carry on doing it anyway. 20Q.
[Mr Rampton]
Nudge nudge, wink wink, we are going to do it more 21quietly. 22A.
[Mr Irving]
Yes. 23Q.
[Mr Rampton]
It is perfectly plausible. 24A.
[Mr Irving]
I am glad you accept this. 25Q.
[Mr Rampton]
That is quite a different thing from suppressing it 26entirely and perverting its meaning into something

. P-106

1different. 2A.
[Mr Irving]
I do not accept that I have done that. 3Q.
[Mr Rampton]
Which is what you have done. 4A.
[Mr Irving]
I do not accept that. 5Q.
[Mr Rampton]
Very well. 6MR JUSTICE GRAY: Whatever it means, it is not Altemeyer 7saying, well, we are going, as it were, off our own bat, 8carry on as before, because the words make it plain it is 9part of the order that the mass shootings shall be carried 10out more discreetly in the future. 11A.
[Mr Irving]
When I am writing this up, and also when I am talking 12about it, I am not just taking this document into account, 13I am taking into account what we know at both other ends 14and also the killing of the Germans thereupon stopped. 15MR JUSTICE GRAY: Yes. Right. 16A.
[Mr Irving]
Thank you. 17MR JUSTICE GRAY: Will you show Mr Rampton if you want to 18pursue the Stuttgart business. 19A.
[Mr Irving]
After lunch. 20MR JUSTICE GRAY: Provide it to him. 5 past 2. 21(Luncheon adjournment)22MR JUSTICE GRAY: Mr Irving and Mr Rampton, it is court 73 as 23from Monday. There were problems about Chichester Rents 24that made it unsuitable. 25MR IRVING: Thank you very much, my Lord. My Lord, first, one 26minor matter. I have one minor application to make which

. P-107

1I would make about this time tomorrow concerning the date 2of one of the witnesses who is appearing on summons that 3it would be proper to make to your Lordship. 4MR JUSTICE GRAY: Yes, I know. 5MR RAMPTON: He may mean Monday, may he not, my Lord? 6MR JUSTICE GRAY: Yes, Monday. 7MR IRVING: Thank you very much, Mr Rampton. 8MR JUSTICE GRAY: We are going to review whether we sit on 9Fridays, but for the moment I think it probably is, in 10everybody's interests to have, not least yours, Mr Irving, 11actually. 12MR IRVING: Thank you very much, my Lord. My Lord, you will 13have seen the press clipping which I put to you this 14morning ---- 15MR JUSTICE GRAY: Yes, I did. 16MR IRVING: --- from the German newspaper. I will not read it 17out. 18MR JUSTICE GRAY: Have you seen it, Mr Rampton? 19MR RAMPTON: Yes, I have. 20MR IRVING: It refers to the year 1996. According to this 21press clipping, the German government have asked for my 22extradition to Germany on an allegation, an alleged 23offence that I committed in 1990. The substance of the 24allegation is neither here nor there. I am only concerned 25with the coincidence of time; the fact that after 10 years 26suddenly this should have occurred now, just as our action

. P-108

1here is being heard. 2MR JUSTICE GRAY: I do not want to cut you short, but I rather 3sympathise with your view that it is unlikely to be a pure 4coincidence, but what on earth can I do about it? 5MR IRVING: Put my mind at rest, my Lord. If we could ask the 6Defendants whether they have had any advance or prior 7knowledge in any way at all of this or whether they were 8contacted at all with the prosecuting authorities in 9Stuttgart, or whether they contacted the prosecuting 10authorities. 11 The reason I have to say this, my Lord, is 12because, as my discovery shows, one of the bodies which 13I mentioned in my opening statement has corresponded in 14the past with both the German Embassy and the Austrian 15Embassy asking for my arrest. 16MR JUSTICE GRAY: I am not going to compel Mr Rampton to stand 17up and give an answer to that question. There are two 18ways in which you can deal with it if you want to pursue 19it, and I do not myself feel that you would be well 20advised to do so, but if you want to pursue it, you can 21either lay the foundations in your own evidence for me 22to draw the inference that it must have had something to 23do with the Defendants -- that is one way of dealing with 24it -- or you can cross-examine whichever of the 25Defendants' witnesses you think would be able to answer 26your questions on this topic.

. P-109

1 I appreciate you understand that Professor 2Lipstadt will not be being called to give evidence so you 3will not be able to ask her, but there may be other 4witnesses, I do not know, who are going to be called by 5the Defendants whom you could ask. But, to be candid, my 6feeling is that we have quite enough to gnaw on this in 7this case without really going down what are effectively 8side alleys. 9MR IRVING: Very well. I did wish to draw it to your 10Lordship's attention in case the morning should arrive 11when this end of the bench was suddenly empty. 12MR JUSTICE GRAY: If that were to happen (which I think is 13unlikely) I will do my best to prevent it. Does that 14help? 15MR RAMPTON: So indeed would I. Although your Lordship said 16you are not going to compel me to answer, but if I may 17respectfully say so, rightly, Mr Irving did ask me to 18ask. I did ask and the answer is no. 19MR JUSTICE GRAY: There you are. You do not have to accept 20that, but that is what you are told. 21MR IRVING: Quite clearly, I am sure that Mr Rampton would not 22have made that statement if it was in any way ^^-- I will 23accept that assurance, but I will also advance this 24particular episode as an instance of the kind of hatred 25that I have faced and the problems that I have faced in 26view of the allegations and the repugnant suggestions made

. P-110

1by this Defendant and others. 2MR JUSTICE GRAY: You have dealt with that very clearly in your 3evidence and, of course, I have that well in mind. 4MR IRVING: It has a certain actuality about it which is quite 5impressive. 6MR JUSTICE GRAY: That is true. Yes, if you would like to go 7back? 8MR DAVID IRVING, continued. 9Cross-Examined by MR RAMPTON, QC, continued.10MR JUSTICE GRAY: Mr Rampton, have we finished, at any rate for 11the time being, with H17, because if so I will hand it 12back because I have your copy. That is the German version 13of Bruns' statement. 14MR RAMPTON: Yes. I am afraid I have not quite finished with 15Bruns. I thought I had, but, as usual, that is the 16trouble with adjournments; things occur to one that one 17might have asked and did not. But, for completeness, 18I will ask. (To the witness): Mr Irving, do you still 19have there the file D3(i) which is the file of published 20articles or talks by you? 21A.
[Mr Irving]
D3(i), yes. 22Q.
[Mr Rampton]
I am looking at tab 30 which is the print of your speech, 23the JHR conference in October '92. 24A.
[Mr Irving]
Yes. 25Q.
[Mr Rampton]
And the questions which followed it. You remember -- you 26need not look it up, but it is on page 24, if you want of

. P-111

1tab 30, internal page 24, not final page 24 -- I drew your 2attention towards the bottom of the left-hand column to 3the words in quotes as a report of what Bruns had said 4that Altemeyer had said: "These mass shootings have got 5to stop at once". Do you remember that this morning? 6A.
[Mr Irving]
Yes. 7Q.
[Mr Rampton]
And I think your answer was to this effect, that it was 8justified anyway but you could not rely on a transcript of 9an extemporary answer to a question. I am summarizing. 10I am not quoting your words directly. 11A.
[Mr Irving]
On this transcript of my extemporary answer? 12Q.
[Mr Rampton]
Yes, on this example? 13A.
[Mr Irving]
Yes, that it would be -- yes, continue. 14Q.
[Mr Rampton]
Is it right, Mr Irving, that, in fact, before this version 15of your words as printed in this way, you went through 16them and approved them? 17A.
[Mr Irving]
Occasionally I did. 18Q.
[Mr Rampton]
This particular article? 19A.
[Mr Irving]
I am sure, Mr Rampton, you will be able to refresh my 20memory; if I did, then I did. 21Q.
[Mr Rampton]
You have recently told us so in your answers to our 22requests for information. 23A.
[Mr Irving]
I do not want to be specific about this one, and I am not 24being clever, but frequently they would send me a 25transcript to read, and sometimes I would proof read it 26and send it back and sometimes I would not.

. P-112

1Q.
[Mr Rampton]
You are right to be cautious, Mr Irving, not because I am 2setting traps, but because memory is fallible. You served 3on us, that is to say, our side, something called --- 4A.
[Mr Irving]
"Answers to requests for information". 5Q.
[Mr Rampton]
"Some answers". 6A.
[Mr Irving]
Yes. 7Q.
[Mr Rampton]
Fair enough because there were only some answers, on 27th 8December of last year? 9A.
[Mr Irving]
Yes. 10Q.
[Mr Rampton]
And one of the answers was this. This is No. 13 on page 115, my Lord. It is tab 9 of the main pleadings bundle, 12A1. 13MR JUSTICE GRAY: Yes, I do not think I have it. 14MR RAMPTON: No, but it does not matter; it is very short. Is 15very short. (To the witness): "In October 1992 I spoke 16at an IHR conference"? 17A.
[Mr Irving]
Is that this one? 18Q.
[Mr Rampton]
Yes. It is the only one I know of in October 1992. "As 19on previous occasions, I attended my booked table and paid 20no attention to the other speakers. Once again 21I corrected the text of my talk before it was published." 22A.
[Mr Irving]
Very well, yes. 23Q.
[Mr Rampton]
Also it is right to say, is it not, that the whole of 24that, including the questions and answers, appears on your 25web site? 26A.
[Mr Irving]
The whole of this?

. P-113

1Q.
[Mr Rampton]
Yes. 2A.
[Mr Irving]
No, it is not correct to say that. 3Q.
[Mr Rampton]
It is not? 4A.
[Mr Irving]
No, it is not correct. 5Q.
[Mr Rampton]
That particular passage does, does it not? 6A.
[Mr Irving]
Will you give me the web site address? 7Q.
[Mr Rampton]
Yes, I will. In fact, I had better you see the hard copy. 8A.
[Mr Irving]
Www. 9Q.
[Mr Rampton]
File D2(iii). It is HTP.www.fpp.co.uk.speeches. 10Speech ---- 11A.
[Mr Irving]
Yes. 12Q.
[Mr Rampton]
--- 111092 HTML? 13A.
[Mr Irving]
In that case, that is correct, but does this particular 14passage also appear on that or just the speech? 15Q.
[Mr Rampton]
Yes, it does. I have the page here. By all means, I will 16pass it up. 17MR JUSTICE GRAY: I think you will take that on trust, I 18suspect, will you not? 19MR RAMPTON: You can trust me if I say something like that. 20A.
[Mr Irving]
No, the reason I say that is because in some of the 21witness reports things have been said to be on my web site 22whereas, in fact, they are just links on my we site 23somewhere else. 24MR JUSTICE GRAY: Anyway, do not let us take more time on this. 25I think it is accepted it is on the web site. 26MR RAMPTON: I think the answer is yes.

. P-114

1MR JUSTICE GRAY: Yes, it is. 2MR RAMPTON: So, first of all, you corrected the transcript of 3the talk before ---- 4A.
[Mr Irving]
Yes. 5Q.
[Mr Rampton]
--- it was published and, secondly, you put the whole 6thing in that form on to the web site? 7A.
[Mr Irving]
Without in any way reviewing it. 8Q.
[Mr Rampton]
No, I understand that, but the fact is we can then take it 9that you have no quibble with the quotation marks around 10the words "These mass shootings have to stop at once"? 11A.
[Mr Irving]
Not the kind of thing I would quibble about, I do not 12think, no. 13Q.
[Mr Rampton]
Quite, good, I an glad to hear. There is one more, 14slightly more substantial point that I want to go back to 15which I apologise for having missed this morning. I am 16grateful it has been drawn to my attention. Have you got 17your 1977 "Hitler's War" with you there? 18A.
[Mr Irving]
1997? 19Q.
[Mr Rampton]
In 1977? 20A.
[Mr Irving]
Yes, I have. 21Q.
[Mr Rampton]
I am apt to '97 when I mean 1977, excuse me. 22A.
[Mr Irving]
This is the English edition of it, yes. 23Q.
[Mr Rampton]
Yes. I think the words are probably the same though, are 24they not? 25A.
[Mr Irving]
The English and American, yes. 26Q.
[Mr Rampton]
Page 332?

. P-115

1A.
[Mr Irving]
Yes. 2Q.
[Mr Rampton]
I am not going to read it again. We have heard it too 3often. In the middle of the page, there is the passage 4dealing with the Berlin Jews, is there not? 5A.
[Mr Irving]
Yes. 6Q.
[Mr Rampton]
You have written: "The fate of Berlin's Jews was clearly 7raised". So the context of that passage is, at any rate, 8foreshadowed as being Berlin's Jews, is it not? 9A.
[Mr Irving]
The context of the paragraph is the prior responsibility 10of the SS for the murders and not Hitler. 11Q.
[Mr Rampton]
Sure. 12A.
[Mr Irving]
Yes. 13Q.
[Mr Rampton]
But we are talking here in this little bit about a 14discussion about Berlin's Jews between Hitler and Himmler? 15A.
[Mr Irving]
Yes, in that sentence. 16Q.
[Mr Rampton]
Yes. Then you say in the next sentence: "At 1.30 p.m. 17Himmler was obliged to telephone from Hitler's bunker to 18Heydrich the explicit order that Jews were not to be 19liquidated"? 20A.
[Mr Irving]
Yes. 21Q.
[Mr Rampton]
Let me ask you this. You remember what you put in the 22introduction? 23A.
[Mr Irving]
Yes. 24Q.
[Mr Rampton]
When you wrote that, did you mean to say that these Berlin 25Jews or Berlin's Jews in general were were not to be 26liquidated, or that Hitler had made a general prohibition

. P-116

1against the slaughter or murder of Jews anywhere? 2A.
[Mr Irving]
It is nit-picking. 3Q.
[Mr Rampton]
It is not. 4A.
[Mr Irving]
What I am about to say is nit-picking. 5Q.
[Mr Rampton]
Oh, I see. 6A.
[Mr Irving]
But there is a period after the word "Judentransport aus 7Berlin", Jew transport from Berlin. In other words, there 8is a full stop at the end of that and a new line. Then 9comes the phrase "Keine Liquidierung" as a separate 10phrase. Operating as we were at that time, 1977, totally 11in the darkness about this particular -- we now know a lot 12more, but at that time we were operating totally in the 13darkness. I was going through a jungle of new documents 14that no other historian had set foot in. It was perfectly 15rational to say, is the "Keiner Liquidierung" a phrase 16which is attached to the line above, or is it a separate 17subject; just in the same way, if you look, there are four 18lines in that facsimile. The first one is -- I will say 19it in English so we have no problem -- arrest of 20Dr Jakelius. The next line after a period is "Apparently 21son of Molotoff" or "apparent son of Molotoff". The next 22line is "Jews transport from Berlin", full stop. The next 23line is "No liquidation". 24Q.
[Mr Rampton]
Yes. 25A.
[Mr Irving]
I appreciate that in the light of our present knowledge 26the fourth line clearly refers to the third line. Are you

. P-117

1with me, Mr Rampton? 2Q.
[Mr Rampton]
I am absolutely with you, Mr Irving. Carry on. 3A.
[Mr Irving]
But in the state of my knowledge in 1977, when I am still 4in darkest jungle of new documents, it was perfectly 5reasonable to accept the fourth line as being as detached 6from the third line line as were the first and second 7lines from each other and from the rest. 8MR JUSTICE GRAY: So answer to Mr Rampton's question is that 9you were conveying in that passage what you thought was an 10explicit order relating to Jews generally, not just Berlin 11Jews? 12A.
[Mr Irving]
Based solely on the fourth line with Jews being the topic 13of conversation, my Lord, yes. 14MR RAMPTON: I am coming back to that. 15A.
[Mr Irving]
That is why the full stop is so important. 16Q.
[Mr Rampton]
You say that, but it has this possible effect as well 17which is something evidently you did not even pause to 18think about; it might not have had anything to do with 19Jews at all, might it? 20A.
[Mr Irving]
You are absolutely right. 21Q.
[Mr Rampton]
You inflated it on the basis of what one might call a 22speculative inference into a general order against the 23liquidation of Jews in general, did you not? 24A.
[Mr Irving]
I object to the word "inflated". I said that 25I interpreted that line from the clear evidence that the 26previous topic of conversation had been Jews.

. P-118

1Q.
[Mr Rampton]
Berlin's Jews? 2A.
[Mr Irving]
Yes, Jews all the same. I interpreted the fourth line as 3being a reference to "no liquidation". We now know that 4this was, in all probability, a reference purely to that 5train load. 6Q.
[Mr Rampton]
We do not want to get ahead of ourselves, at least I do 7not want to get ahead of myself, Mr Irving, though you 8should not feel sorry for me. 9A.
[Mr Irving]
Right, but please do not forget that full stop in the line 10above. 11Q.
[Mr Rampton]
Of course I do not forget it. I can see it in the 12original. 13A.
[Mr Irving]
We had a lot of discussion about whether the "K" of 14"Keine" was actually a large "K" or a little "k" among 15historians, believe it or not. 16MR JUSTICE GRAY: If you have a full stop, it does not matter? 17A.
[Mr Irving]
Well, people wondered if that was a full stop or a 18blemish, my Lord. This is the kind of level to which one 19sinks. 20MR RAMPTON: The fact is, Mr Irving, that full stop or no, the 21first line of those two lines concerns Jews from Berlin, 22as it happens, one transport? 23A.
[Mr Irving]
Well, it concerns Jew transport or transportation from 24Berlin. 25Q.
[Mr Rampton]
The second line, if it is to be read disjunctively from 26the first line, refers to "no liquidation". No

. P-119

1liquidation of what? Businesses, gypsies? 2A.
[Mr Irving]
It would have to be a very perverse mind indeed which 3accepted there was no connection between the fourth and 4the third lines, general topic. 5Q.
[Mr Rampton]
The natural meaning of those two lines taken together, 6whether you insert the full stop or not, is that there is 7to be no liquidation of the Jews from Berlin? 8A.
[Mr Irving]
You say whether you accept the full stop or not; the full 9stop is there. 10Q.
[Mr Rampton]
No difference. It might have been a ---- 11A.
[Mr Irving]
Pardon? 12Q.
[Mr Rampton]
There might have been nothing. It is a note in a man's 13handwritten telephone log. 14A.
[Mr Irving]
I agree. One cannot put it on the gold balance. 15Q.
[Mr Rampton]
If you say, Mr Irving, the "liquidieren" refers to Jews at 16all, then it is most probable, most probable -- I do not 17have to deal in certainties, you see, Mr Irving -- that it 18refers to the Jews referred to in the previous line, is it 19not? 20A.
[Mr Irving]
Yes. 21Q.
[Mr Rampton]
Yes. So why, what was the warrant for your inflating this 22(and I use that word advisedly because it is an inflation, 23objectively regarded) into a prohibition against the 24liquidation of all Jews anywhere? 25A.
[Mr Irving]
I remind you of your previous question; you are saying it 26is most likely that it was, and you are talking in the

. P-120

1present tense, but was it most likely in 1977 when I wrote 2the book or published the book? 3Q.
[Mr Rampton]
I am looking at the German as it was written in 1941. 4A.
[Mr Irving]
No, are you asking me was it most probable that the fourth 5line referred to the third line in the 1960s when I wrote 6the book? The answer to that is it not so likely, it is 7not so evident because at that time we did not have the 8documents that we do now. 9Q.
[Mr Rampton]
Ignore the extraneous material completely, if you will, 10Mr Irving. 11A.
[Mr Irving]
You cannot when you are writing books. 12Q.
[Mr Rampton]
I will. I am trying to get back to your state of mind in 131970 something when you first wrote this passage which got 14replicated in 1991. I look at what you had in front which 15you told us this morning was just the sheet. You did not 16have the surrounding material. German is an ordinary, 17Western European language. They think like us, they speak 18somewhat like us, and the entry is: "Jew transport from 19Berlin", full stop, "no liquidation". Now, if the 20"liquidation" refers to Jews, it refers to those Jews and 21no other Jews? 22A.
[Mr Irving]
Mr Rampton, you have four topics referred to in that 23conversation, one, two, three and four. One, two and 24three are all totally different topics from each other, 25and it is very reasonable to assume that the fourth topic 26is probably also yet another fourth topic.

. P-121

1Q.
[Mr Rampton]
That is interesting. 2A.
[Mr Irving]
But you say there was no other document before me at that 3time. Of course, there were the rest of these telephone 4logs. For example, the reference to "no destruction of 5the gypsies" which clearly shows the way which decisions 6are going at the top. 7Q.
[Mr Rampton]
So you mean the fourth line, "Keine Liquidierung" could 8refer to the verhaftung of Dr Jakelius? 9A.
[Mr Irving]
Equally. 10Q.
[Mr Rampton]
What is the verhaftung of Dr Jakelius? 11A.
[Mr Irving]
The arrest of Dr Jakelius. Dr Jakelius, my research has 12established, was an euthanasia doctor in Vienna who had 13been arrested for some reason. 14Q.
[Mr Rampton]
OK. He has been arrested. What is the Angleblich 15Molotoff? 16A.
[Mr Irving]
Somebody who was, apparently, claiming to be a son of 17Molotoff. Molotoff, the Foreign Minister, had no sons. 18Q.
[Mr Rampton]
And then there is the "Judentransport aus Berlin"? 19A.
[Mr Irving]
Then come -- yes. 20Q.
[Mr Rampton]
Then the fourth line is "Keine Liquidierung", so this 21could mean that none of those three groups, categories, is 22to be liquidated. Is that what you are telling us? 23A.
[Mr Irving]
I do not think I said that. I am saying that all four 24lines can be taken separately because the first three 25lines are quite clearly separate topics from each other. 26Q.
[Mr Rampton]
Let us go through it. Plainly, it is an utter nonsense to

. P-122

1talk about the "angeblich sohn Molotoff" as being subject 2to an injunction against liquidation, is it not? 3A.
[Mr Irving]
Subject to? 4Q.
[Mr Rampton]
Being subject to an injunction against liquidation? 5A.
[Mr Irving]
Well, very clearly it is. If somebody was the son of a 6prominent Soviet leader, they would definitely be kept in 7a very special confinement. 8MR JUSTICE GRAY: He was thought at one time to have been on 9that train. 10A.
[Mr Irving]
The usual trick was that a prisoner would be taken and he 11would claim to be Churchill's son or nephew or cousin or 12something like, and knowing that they would not be able to 13kill him. But it would be dangerous to read too much just 14into three words. All we know is that Molotoff had no 15sons and that, obviously, there is no connection between 16the Jakelius and Molotoff. 17MR RAMPTON: No, but, of course, there is no full stop after 18"Jakelius" either, is there, so it might be asserted that 19he was arrested because he was pretending to be the son of 20Molotoff, might he not? 21A.
[Mr Irving]
I am not sure how much time the court wishes to... 22MR RAMPTON: Well, this is fanciful. 23MR JUSTICE GRAY: I am wondering whether we have not thrashed 24through this document sufficiently. 25MR RAMPTON: Is it not? The "Keine Liquidierung" refers to the 26"Judentransport aus Berlin" whether there is a full stop

. P-123

1or not. 2A.
[Mr Irving]
This is your opinion, but it is not mine, Mr Rampton, when 3I am writing my book in early 1970s and ---- 4MR JUSTICE GRAY: It comes to this. In the early 1970s you 5took that, as you now accept wrongly, to have been a 6reference to Jews generally? 7A.
[Mr Irving]
At large or at larger than is justified. I took it to be 8transportation, the transporetation of the Jews as ---- 9MR RAMPTON: No, in the introduction it is "at large", not "at 10larger". In the introduction it is all Jews. 11A.
[Mr Irving]
Yes. This was the inference that I drew ---- 12Q.
[Mr Rampton]
This is the incontrovertible evidence that Hitler had 13ordered, no liquidation of any Jews anywhere. 14A.
[Mr Irving]
Into account I take when writing that sentence my entire 15expertise based on all the other documents that we have by 16that time already collected, and, of course, now we know a 17great deal more which proves I was absolutely right to 18write what I wrote at that time. 19Q.
[Mr Rampton]
Mr Irving, we are not here to find out whether you were 20right or wrong; if we were, we would be here until the 21next Millennium. 22A.
[Mr Irving]
I doubt it. 23Q.
[Mr Rampton]
No doubt. We are here to test your credentials, your 24honesty and your integrity, as an historian, a chronicler 25of these events. The proposition which I put to you for 26you to deny is that you deliberately distorted the sense

. P-124

1of these two lines so as to make the reference to "Keine 2Liquidierung" without any warrant whatsoever appear to be 3a reference to Jews everywhere? 4A.
[Mr Irving]
This sentence would only stand up in court, in my view, if 5you were able to establish that at the time I wrote those 6sentences I knew different and better. I think it would 7be very difficult to make that stand. To show that one 8makes a mistake in interpreting a translation of the word 9"transport", that one chooses the wider interpretation 10rather than the narrow narrower definition that we now 11know to be correct from the other documentation, this is 12not a deliberate wilful and perverse distortion or 13manipulation or translation of a document. 14Q.
[Mr Rampton]
I put it to you, Mr Irving, that, on the contrary, it 15quite plainly is -- shall we leave it there -- which you 16deny? Just while we are on the question of full stops, 17since you have raised it, if we go to page 14 in your 18little bundle, we see the rather worse photograph, 19I agree, of the same sort of document that the log for the 20beginning of December, the first day of December? 21A.
[Mr Irving]
Precisely, yes. 22Q.
[Mr Rampton]
Yes, and I do not know, this is not a very good copy, are 23you certain whether or not there is a full full stop after 24word ---- 25A.
[Mr Irving]
"SS"? 26Q.
[Mr Rampton]
--- "Verwaltung", yes, "SS"?

. P-125

1A.
[Mr Irving]
The second rune, you know what I mean by the rune, the 2lightening flash that the SS ---- 3Q.
[Mr Rampton]
Yes, SS thing. 4A.
[Mr Irving]
--- the second rune is right off the photocopy. 5Q.
[Mr Rampton]
I know. 6A.
[Mr Irving]
So we cannot tell if there is a full stop or not. 7Q.
[Mr Rampton]
Have you got the original? 8A.
[Mr Irving]
I have got it in my volume at the end -- the blue volume 9marked "Himmler Diary". 10Q.
[Mr Rampton]
Have you got that printed transcript of these documents? 11MR JUSTICE GRAY: It is in this file, is it not? 12A.
[Mr Irving]
Well, I am afraid that I do not trust this ---- 13Q.
[Mr Rampton]
OK. 14A.
[Mr Irving]
--- to that degree. Let me just explain why I will not 15trust this for being that kind of evidence. On two or 16three occasions I spotted instead of writing "u." for 17"und", they have written out "Und" in full. 18Q.
[Mr Rampton]
My fault entirely. I used the wrong document. One does 19make mistakes. I quite agree. Turn back to page 13 of 20your own documents, will you? This is your carefully 21retranscribed version of the Himmler log? 22A.
[Mr Irving]
Yes. 23Q.
[Mr Rampton]
Where you correct the mistake "Juden" to read properly 24"haben"? 25A.
[Mr Irving]
"Haben" with a small "h". 26Q.
[Mr Rampton]
And there is no full stop after "SS", is there?

. P-126

1A.
[Mr Irving]
It would have been highly improper of me to have put a 2full stop in if there was not one visible on the 3photocopy. 4Q.
[Mr Rampton]
Exactly. What would in German the sentence or phrase 5(because is not really a sentence) "VerwaltungsFuhrer der 6SS haben zu bleiden" mean -- I mean "Juden zu bleiden", 7I beg your pardon. What would it mean? 8A.
[Mr Irving]
Jews to remain. 9Q.
[Mr Rampton]
No, no. I will read it in English: "Administrative 10officers, leaders, of the SS Jews to remain"? 11A.
[Mr Irving]
Read like that, it would mean nothing at all. It would be 12quite meaningless. 13Q.
[Mr Rampton]
Exactly. It would be a complete nonsense, would it not? 14A.
[Mr Irving]
Yes. 15Q.
[Mr Rampton]
Thank you. Be patient with me, Mr Irving. I am just 16going to a new topic now. Mr Irving, you are conscious, 17I suppose and, in fact, I know you are, that Adolf Hitler 18made a speech I think to Reich and Gauleiters in Berlin on 1912th December 1941. I am still in the same period of 20short period of history. 21A.
[Mr Irving]
4th December? 22Q.
[Mr Rampton]
Yes, 12/12/41. 23A.
[Mr Irving]
Yes. 24Q.
[Mr Rampton]
We know that because there is a report of it in Goebbels' 25diary for 13th December, is there not? 26A.
[Mr Irving]
There is a reference to it.

. P-127

1Q.
[Mr Rampton]
Yes. Well, there is rather more than that, I think. Have 2you got -- have you got your Goebbels book there? 3MR JUSTICE GRAY: The answer is "no" can he be provided with a 4copy? 5MR RAMPTON: Yes, please somebody give him a Goebbels. 6A.
[Mr Irving]
It is here. I have it here. 7Q.
[Mr Rampton]
If you turn to page 383 you see in the first complete 8paragraph you start like this: "Addressing the... whilst 9still in Berlin Hitler opted for greater candour. He 10confessed that he had spent sleepless nights... whether he 11was doing the right thing in declaring war on Roosevelt." 12 Then you quote Goebbels: "The Fuhrer" Goebbels 13reported to his diary "is convinced that he would have had 14to declare war on the Americans sooner or later. Now the 15conflict in the Far East drops into our laps as an added 16bonus". "He viewed the battle of the Atlantic" etc. etc. 17down to the end of paragraph "an unavoidable hitch". 18Footnote 72. In footnote 72, which is on page 646, you 19explain that those references are taken from Goebbels 20diary on 13th December. 21A.
[Mr Irving]
That is correct, and that is true. 22Q.
[Mr Rampton]
Yes. 23MR JUSTICE GRAY: Mr Rampton, I am sorry, what page? 24MR RAMPTON: 646, the footnote. 25MR JUSTICE GRAY: No, what page in the text? 26MR RAMPTON: 383, I am so sorry.

. P-128

1A.
[Mr Irving]
The second paragraph. 2Q.
[Mr Rampton]
Then I ask you to note, I will wait until his Lordship has 3it, I ask you to note on the same page in the second part 4of the next paragraph these words, because I am coming 5back to this: "Returning by train on December 16th to the 6Wolf's Lair" yes? 7A.
[Mr Irving]
Yes. 8Q.
[Mr Rampton]
So that you are saying means that -- I take it what are 9you saying means that Hitler having addressed the 10Gauleiters on the 12th went back to the Wolf's Lair in 11East Prussia on the 16th? 12A.
[Mr Irving]
Yes, I can easily check it from the war diary. 13Q.
[Mr Rampton]
No. I am sure you are right about that, I am not about to 14dispute it, you will be surprised to hear. 15 Could you now please be provided with a copy of 16Professor Evans' report? No, I am sorry that is the wrong 17reference I beg your pardon. Can somebody retrieve that 18mistake by me, and give Mr Irving Professor Longerich. 19MR JUSTICE GRAY: This point is dealt with by Evans? 20MR RAMPTON: I know it is, but I have not got the reference in 21Evans. 22MR JUSTICE GRAY: I think it is page 320. 23MR RAMPTON: I have put it away. 24A.
[Mr Irving]
I am looking forward to it actually. 25MR JUSTICE GRAY: What? 26A.
[Mr Irving]
I am looking forward to it.

. P-129

1MR RAMPTON: It is very well known passage in Goebbels diary, 2or seems to be. Thanks perhaps in part to Mr Irving, 3I know not. If you have got Dr Longerich's report now, 4could you turn to page 61 of the first part? 5A.
[Mr Irving]
Yes, I have it. 6Q.
[Mr Rampton]
We are on 12th December still. His report reads as 7follows, at the bottom of page 61, paragraph 17.3: "One 8day after the declaration of war on the USA on 12th 9December Hitler addressed the... of the party"; so far is 10that correct, Mr Irving? 11A.
[Mr Irving]
That is correct, yes. 12Q.
[Mr Rampton]
"In this speech he returned once again to prophecy of 30th 13January 1939", that is the one in the Reichstarget about 14the fate of Jews, is it not? 15A.
[Mr Irving]
Yes. 16Q.
[Mr Rampton]
"And now announced the approaching extermination of the 17Jews living under German domination, as we can read in the 18Goebbels diaries." 19 Now please look at footnote 156, and I am not 20going to read it out because that is a strain for me and 21worst still for the transcribers. It is the original 22German. Tell me if it is accurate, your German is very 23good. 24A.
[Mr Irving]
The German text is accurate apart from the fact it has 25transcribed some of the diacriticals incorrectly. 26Q.
[Mr Rampton]
Fair enough.

. P-130

1A.
[Mr Irving]
German SZ, things like that. 2Q.
[Mr Rampton]
You have read it now, have you? 3A.
[Mr Irving]
I read it and I disapprove of the translation, but we will 4reach that moment. 5Q.
[Mr Rampton]
We will come to that because that is over the page, but -- 6A.
[Mr Irving]
It is a tendentious translation. 7MR JUSTICE GRAY: But nothing wrong with the German? 8A.
[Mr Irving]
-- nothing wrong with German -- 9MR RAMPTON: I will come back, because the translation will be 10important many times during in the course of the case. 11Dr Longerich translates it at the top page 62. 12A.
[Mr Irving]
-- he is, of course, German translating into English. 13Q.
[Mr Rampton]
I know he is, but it may be, I know not, you can ask him 14when he comes to court. He had some help. His English is 15pretty good, but not perfect: "As concerns the Jewish 16question the Fuhrer is determined to make a clean sweep"; 17what I suggest we do, Mr Irving, is to take out page 61 18and fortunately the German text is on a separate page. 19A.
[Mr Irving]
Right. 20Q.
[Mr Rampton]
As we go through the English you can tell me in answer to 21my questions where you think Dr Longerich has gone wrong 22in his translation. 23A.
[Mr Irving]
Yes. 24Q.
[Mr Rampton]
"As concerns the Jewish question the Fuhrer is determined 25to make a clean sweep" (German spoken)? 26A.
[Mr Irving]
Tabula rasa they say in Latin.

. P-131

1Q.
[Mr Rampton]
Maybe, but this is fortunately in these courts we do not 2speak much Latin any more. 3MR JUSTICE GRAY: No, but it is closer actually, the Latin than 4the English. 5MR RAMPTON: Probably. 6MR JUSTICE GRAY: That is the point are you making. 7A.
[Mr Irving]
Yes. 8MR RAMPTON: Yes, a tabular rasa is a blank surface. 9A.
[Mr Irving]
So I am more accurate than yourself -- 10MR JUSTICE GRAY: There is no distinction in terms of the sense 11of it, is there. 12MR RAMPTON: I do not know. 13A.
[Mr Irving]
-- does the word tabula rasa exist in English? 14MR RAMPTON: Yes. It is frequently used by people who do not 15know what it means, as so much Latin is. But if you wish 16tabula rasa is rather a perhaps stronger word than "clean 17sweep". 18A.
[Mr Irving]
Cleansing. 19MR JUSTICE GRAY: Do you dispute clean sweep gives sense? 20A.
[Mr Irving]
Not at all, perfectly good line. 21MR RAMPTON: "He had prophesied to the Jews that if they once 22again brought about a world war they would experience 23their own extermination." The words in German are (German 24spoken); what do those words mean? 25A.
[Mr Irving]
Well, of course, to translate "vernichtung" as 26extermination is highly tendentious.

. P-132

1Q.
[Mr Rampton]
Why? 2A.
[Mr Irving]
If you look in your yellow dictionary, see what 3"vernichtung" says. 4Q.
[Mr Rampton]
I think I will. 5A.
[Mr Irving]
I have no idea. I am prepared to say meaning No. one is 6extermination. 7Q.
[Mr Rampton]
You do not have to say that, Mr Irving. The root of the 8word is "making to nothing" annihilating, is it not? Let 9us see what that says. I have very little knowledge of 10German, but it seems to me obvious, but it means, 11according to Langscheidt, annihilate, destroy, 12exterminate, eradicate-shatter. 13A.
[Mr Irving]
It is the third possible meaning and he has chosen the 14third meaning rather than the first. 15Q.
[Mr Rampton]
Did you see a distinction -- 16A.
[Mr Irving]
Yes -- 17Q.
[Mr Rampton]
In this context -- weight between annihilate and 18exterminate? 19A.
[Mr Irving]
-- I am not going to put the words on the gold balance 20because this is not Hitler speaking, this is Goebbels 21reporting, am I correct? 22MR JUSTICE GRAY: No. 23MR RAMPTON: Apparently -- 24A.
[Mr Irving]
On the following day. 25MR RAMPTON: Unless it come from Goebbels diary? 26A.
[Mr Irving]
-- this is Goebbels diary. This is a third person report

. P-133

1by Goebbels of what Hitler said the previous day. 2MR JUSTICE GRAY: He is reporting what he recalls him having 3said. 4A.
[Mr Irving]
Yes, so it is rather meaningless to attach too much 5importance to the actual words contained in the diary. 6MR RAMPTON: On the contrary, Mr Irving, often enough in the 7course of your books you attach a kind of uncritical 8credulity to the utterances of Dr Goebbels. 9A.
[Mr Irving]
Yes. 10Q.
[Mr Rampton]
Notwithstanding he is merely reporting what somebody else 11has said. Furthermore why should -- Dr Goebbels in 12December 1941 misreport what his leader had said? 13A.
[Mr Irving]
Because if you had read my book with the assiduity that 14I am sure you have you will remember that Dr Goebbels is 15an evil little genius who is capable of lying in the most 16malicious and perverse verse way and he will translate 17every single statement through his own distorted brain. 18MR JUSTICE GRAY: In his own diaries? 19A.
[Mr Irving]
Yes. 20MR RAMPTON: Why? 21A.
[Mr Irving]
This is the way people do things. They have a tendency to 22write down things they wished they had heard. If he 23wished to heard Hitler talking about the extermination of 24the Jews, then he would prefer to use that word when for 25all we know Hitler may have used a different one. I have 26no objection at all, Mr Rampton, when you bring to me the

. P-134

1verbatim transcripts of which there are any number of 2Hitler actually said when he says things that are very 3similar. 4Q.
[Mr Rampton]
We do not have -- 5A.
[Mr Irving]
We should not rely on this kind of second order evidence 6on matter of this importance. 7Q.
[Mr Rampton]
-- you do it repeatedly when it suits your book, 8Mr Irving. 9A.
[Mr Irving]
You are accusing me of double standards. 10Q.
[Mr Rampton]
Yes, I am most roundly. 11A.
[Mr Irving]
I disagree. I am very careful with the criteria I apply. 12In a matter like this of such importance I look at the 13actual translations with greatest detail and if they are, 14I mean in law too you have to give somebody the benefit of 15the doubt when they are ambiguities. You certainly do not 16go for the third meaning of the word rather than first 17meaning. 18Q.
[Mr Rampton]
You see, you continually assume that I am using one 19document, one utterance, to prove the guilt of Adolf 20Hitler. In fact I am trying to do neither, Mr Irving. 21What I am trying to do is to suggest to you that the 22convergence of the evidence of which this is just one 23small example. 24A.
[Mr Irving]
Yes. 25Q.
[Mr Rampton]
Is that on the balance of probabilities, as though it were 26a civil case at court, the reasonable historian would say:

. P-135

1on the balance of probabilities the evidence is that Adolf 2Hitler was at the heart of all of this? Do you follow me? 3A.
[Mr Irving]
It is a rather vague sentence, that Hitler was at the 4heart of all this. 5MR JUSTICE GRAY: I think it probably clear what Mr Rampton is 6getting at, can I put a related question, I would be 7interested to know what your answer is; do you 8"vernichtung" would be a word that would be likely to be 9used if what was being talked of was deportation to 10Madagascar or anywhere else? 11A.
[Mr Irving]
I agree it would not and there are definitely cases where 12word "vernichtung" is used in the sense of murder. For 13example, in the German phrase ( German spoken), the 14destruction of people who are not entitled or should not 15be allowed to live. It is quite definitely a killing 16operation, but there are so much better sources where you 17have the actual transcript of what people are speaking 18that I hesitate to waste the court's time looking at the 19kind of document when undoubtedly you have the verbatim 20transcript of what Hitler said where he uses similar words 21or the same words. 22MR RAMPTON: Fortunately for everybody, Mr Irving, it is not in 23your hands whether the court's time is wasted. If I try 24to waste the court's time I will be told not to, if I am 25thought not to be wasting the court's I will not be told. 26A.
[Mr Irving]
If I was sitting there wearing a wig I would have jumped

. P-136

1to my feet and made this point. 2Q.
[Mr Rampton]
You have made it. 3A.
[Mr Irving]
I am wearing my other hat if I say that. 4Q.
[Mr Rampton]
If you want to invite his Lordship to stop this line of 5cross-examination please do so. 6MR JUSTICE GRAY: Come on, I think you are not asking me to and 7if you did, I would not. 8MR RAMPTON: Thank you. Now then you do not like Dr Goebbels 9use of the word "vernichtung". You are not certain that 10that is a word Adolf Hitler would have used on that 11occasion. 12A.
[Mr Irving]
Well, we know exactly what speech Hitler made on January 1330th 1939, there we have the verbatim text. 14Q.
[Mr Rampton]
Turn back to page 38 of the same report. 15A.
[Mr Irving]
We know exactly what Hitler said there, so why we are 16using a second hand version of a version of it repeated 17four years later. 18Q.
[Mr Rampton]
For the very fact that it was repeated on 12th December -- 19A.
[Mr Irving]
Hitler constantly repeated this speech. 20Q.
[Mr Rampton]
-- please, Mr Irving, be patient and listen to my 21questions. Its importance you may agree is that it occurs 22again on 12th December 1941 at the time when the German 23Jews were being transported in large numbers to the East? 24A.
[Mr Irving]
Yes. 25Q.
[Mr Rampton]
Right. If you go back to 811 of Dr Longerich's report you 26find the relevant English of the Reichstag speech on 30

. P-137

1January 1939? 2A.
[Mr Irving]
I know the speech off by heart. 3Q.
[Mr Rampton]
In that case you will agree that the last words in 4citation are: (German spoken); which means the 5annihilation, extermination or eradication of the Jewish 6race in Europe, does it not? 7A.
[Mr Irving]
Can we just be absolutely certain what German words he 8uses. 9MR JUSTICE GRAY: It is same word, take it from me. 10A.
[Mr Irving]
In German, very well, my Lord, yes. 11MR RAMPTON: It is at the bottom of the page in German (German 12spoken)? 13A.
[Mr Irving]
In this case I would say that the word "race" implies that 14he is not talking about an actual killing operation and 15certainly January 1939 nobody was talking about killing 16Jews. 17Q.
[Mr Rampton]
What does word "genocide" mean, Mr Irving? 18A.
[Mr Irving]
Genocide? 19Q.
[Mr Rampton]
Yes, genocide. 20A.
[Mr Irving]
An English word genocide? 21Q.
[Mr Rampton]
No, it is not English, it is Latin. 22A.
[Mr Irving]
It is not a Latin word, you mean Latin origin? 23Q.
[Mr Rampton]
Yes. What does it mean? 24A.
[Mr Irving]
You explain to the court. 25Q.
[Mr Rampton]
No, you tell me if you know what it means. 26A.
[Mr Irving]
Killing of people by virtue of their race.

. P-138

1Q.
[Mr Rampton]
Yes, it means killing of a race of people. 2A.
[Mr Irving]
Yes. 3Q.
[Mr Rampton]
Is it any different from the "vernichtung" of a "rasa"? 4A.
[Mr Irving]
You destroy races in other ways than killing them. Nobody 5in January 1939 and I would be very surprised if you can 6establish the opposite was talking about killing Jews. 7Q.
[Mr Rampton]
Yes. I am going to go on with this little comparison 8between -- 9A.
[Mr Irving]
Yes. 10Q.
[Mr Rampton]
-- if you forgive me and as long as I am not told by his 11Lordship it is waste of the court's time, but there is 12little comparison between what Dr Longerich has written in 13English and what the original German of Dr Goebbels diary 14was. We have finished with the word "vernichtung erleben 15geben", which means "they would experience", this was not 16just an empty phrase. The German is: "Das is keine frazig 17vasen"? 18A.
[Mr Irving]
That is correct. 19Q.
[Mr Rampton]
What does that convey to you? This was -- 20A.
[Mr Irving]
Dr Goebbels is saying that is not an empty phrase. This 21is not Hitler saying this is an empty phrase, this is 22Goebbels saying it is an empty phrase. 23Q.
[Mr Rampton]
-- so you say. 24A.
[Mr Irving]
Well, this is Goebbels diary. 25Q.
[Mr Rampton]
How do you know it is not a report what Hitler said? 26A.
[Mr Irving]
Let me educate you in the German language. If this was

. P-139

1Goebbels saying this is Hitler saying it would have been 2in the subjunctive. German language reports reported 3speech in the subjunctive. It would be (German spoken) 4not (German spoken) I am sure every German in this room 5would agree with me. 6Q.
[Mr Rampton]
Everything in the rest of this quotation is not 7attributable to Hitler; is that your position? 8A.
[Mr Irving]
We are taking this sentence by sentence; is that correct? 9Q.
[Mr Rampton]
Let go on, the world war is there, the extermination and 10again the words are (German spoken) that is of Jewry, Jews 11in general if you like, must be the necessary 12consequence. (German spoken)? 13A.
[Mr Irving]
Here he has the same word, vernichtung, but he has given 14it a totally different translation, extermination, am 15I right? 16Q.
[Mr Rampton]
What do you mean? 17MR JUSTICE GRAY: No. 18MR RAMPTON: I see the two words "extermination" one on top of 19other. 20MR JUSTICE GRAY: I think you mean different from the 1939 21translation. 22A.
[Mr Irving]
Yes, but the word that is different of course is Judentums 23what does your Langscheidt tell us about that? 24MR RAMPTON: I doubt it has it in, I am not going to bother 25with it. 26A.
[Mr Irving]
Can I ask that you look in Langscheidt because I do not

. P-140

1have a copy here. 2MR JUSTICE GRAY: You accept "Jewry" is the right translation? 3A.
[Mr Irving]
Jewry, Judaism, but not Jews. If somebody talks about 4wiping out Christianity that would be the parallel, my 5Lord. 6MR RAMPTON: This is only Dr Goebbels speaking, does it matter? 7A.
[Mr Irving]
What is the standard dictionary? 8Q.
[Mr Rampton]
You cannot -- we cannot believe a word Dr Goebbels says, 9can we? 10A.
[Mr Irving]
This is your Judentums. 11Q.
[Mr Rampton]
I am just looking to see if it is in, it may be Jewry 12collective... there is a choice Mr Irving, which would you 13like to choose? 14A.
[Mr Irving]
Wiping out Jewry, wiping out Judaism, it is not the same 15as exterminating the Jews this is a manipulated 16translation. 17Q.
[Mr Rampton]
It has Jewry? 18A.
[Mr Irving]
He is saying that this is evidence of the wiping out of 19the Jews. 20Q.
[Mr Rampton]
No, look at it "Jewry" big letters, extermination of 21Jewry? 22A.
[Mr Irving]
Extermination of Jewry. 23Q.
[Mr Rampton]
Yes. 24A.
[Mr Irving]
Is not the same as annihilating Judaism. 25Q.
[Mr Rampton]
No, but the two meanings are both there? 26A.
[Mr Irving]
He has chosen once again the tendentious meaning, which

. P-141

1highly is disreputable for an historian to do. 2Q.
[Mr Rampton]
Perhaps that is because it is consistent with the rest of 3the text? 4A.
[Mr Irving]
No, it is incumbent upon an historian, just as a lawyer to 5give the benefit of the doubt to the person you are 6impugning; am I correct? 7Q.
[Mr Rampton]
No, you are not correct. Not in this case. 8A.
[Mr Irving]
In an ambiguity. 9Q.
[Mr Rampton]
No, there is not ambiguity here -- 10A.
[Mr Irving]
There is a total ambiguity. 11Q.
[Mr Rampton]
Mr Irving, I go back: "He had prophecised to the Jews that 12if they", nothing to do with Judaism, "once again brought 13about a world war they would experience their own" that is 14to say the Jews own extermination "vernichtung", the same 15word in the next sentence. 16A.
[Mr Irving]
This is Dr Goebbels, right? 17Q.
[Mr Rampton]
Yes, yes. 18A.
[Mr Irving]
OK. 19Q.
[Mr Rampton]
No, that is Hitler. 20A.
[Mr Irving]
Hitler as reported four years later by Dr Goebbels. 21Q.
[Mr Rampton]
By Dr Goebbels. The world war is there. The 22extermination of Jewry must be the necessary consequence. 23The one flows quite naturally and logically from the 24other. 25A.
[Mr Irving]
In the first case he has taken the third meaning of the 26word. In the second case he has taken the second meaning

. P-142

1of the word. In neither case has he taken the primary 2meaning of the word, primary translation. If I was to do 3that I think I would be hearing about it shortly in this 4court. 5Q.
[Mr Rampton]
Eradication, extermination, annihilation all mean the same 6thing -- 7A.
[Mr Irving]
I do not think so. I gave an example if one talked about 8eradicating Christianity, drug addiction, you do not go 9about wiping out the drug addicts. 10MR JUSTICE GRAY: I think I have the point. 11A.
[Mr Irving]
-- I think there is room for manoeuvre on something like 12this and it is incumbent on people not to take the evil 13meaning of a word when there are much better sources. 14MR RAMPTON: There is only room for manoeuvre for those who 15want to find room to manoeuvre? 16A.
[Mr Irving]
Like people who pay witnesses for expert cases like this. 17Q.
[Mr Rampton]
I must make a note to prompt you to put that allegation to 18Dr Longerich -- 19A.
[Mr Irving]
I shall, to all the witnesses. 20MR JUSTICE GRAY: Let us press on with the translation. 21MR RAMPTON: This question must be seen without sentimentality 22"die frage ist ohne jede sentimentalat so 23betrachten" correct? 24A.
[Mr Irving]
-- that is a fair translation. 25Q.
[Mr Rampton]
Good. We are not here in order to have sympathy with the 26Jews, "wir sind nicht dasu da, mitlied mit den juden"

. P-143

1correct so far? 2A.
[Mr Irving]
Yes. 3Q.
[Mr Rampton]
"Sondern nur mitleid mit unserem deutschen volk so haben"? 4A.
[Mr Irving]
Just to have sympathy. 5Q.
[Mr Rampton]
Rather we should sympathise with our own German people? 6A.
[Mr Irving]
A loose translation, but I am not tendentious. 7Q.
[Mr Rampton]
If the German people have now once again sacrificed as 8many as 160,000 dead in the eastern campaign, then the 9authors of this bloody conflict must pay with their 10lives (German spoken) authors? 11A.
[Mr Irving]
Yes. 12Q.
[Mr Rampton]
(German spoken) of this bloody conflict, therefore -- with 13their lives -- account for, must account for or pay for? 14A.
[Mr Irving]
Yes, this is Dr Goebbels. 15Q.
[Mr Rampton]
It may be? 16A.
[Mr Irving]
I am sorry it is, because it is not in the subjunctive. 17If it is not in reported speech. If he was reporting what 18Hitler had said, it would be not "hat" but "ete", that is 19the way reported speech is done in German. 20Q.
[Mr Rampton]
You see no ground for thinking that Hitler said anything 21like this? 22A.
[Mr Irving]
This is Dr. Goebbels' gloss on what Hitler had said. 23Q.
[Mr Rampton]
You think it is just a gloss on what Hitler said. Do you 24think it is a invention? 25A.
[Mr Irving]
That is what the language tells us Mr Rampton it is not in 26subjunctive, so it is not him reporting what somebody else

. P-144

1said. 2Q.
[Mr Rampton]
Could you answer my question. 3A.
[Mr Irving]
I have given you the answer. 4Q.
[Mr Rampton]
Do you think it is an invention? 5A.
[Mr Irving]
Is what an invention? He is writing down his own 6opinions. Goebbels -- 7Q.
[Mr Rampton]
None of this is attributable to what Hitler said on this 8occasion when he addressed the Reich and Gau leaders on 912th December -- 10A.
[Mr Irving]
-- Mr Rampton, you do not know and I do not know because 11we do not have a transcript of that speech. 12MR JUSTICE GRAY: How much do you say Mr Irving of this little 13snippet is a report of what Hitler said to the gaulieter? 14A.
[Mr Irving]
-- as I say, in all my editions of Hitler's War, Hitler 15made the original speech on January 30th 1939 and he 16repeatedly and ominously repeated and recorded what he had 17said on that occasion, saying I prophecised then and 18I will say it again and those who laughed then they are 19laughing on the other side of their faces now. This kind 20of thing. He said it something like eight or nine times 21during the war on 8th November 1942 and so on. 22Q.
[Mr Justice Gray]
Answer my question. 23A.
[Mr Irving]
It was one of his stock speeches. So I know with a pretty 24fair degree of certainty how much of this quotation Hitler 25actually said because Hitler was always saying the same 26thing and how much is probably Goebbels adding his own

. P-145

1private gloss. 2MR JUSTICE GRAY: But this is something, this is in part at any 3rate a report by Goebbels of what Hitler said in 1941 to 4the gaulieter? 5A.
[Mr Justice Gray]
I appreciate that, yes. 6Q.
[Mr Rampton]
Nothing to do with 1939. My question, if I can ask you 7for an answer, is how much do you say of this snippet from 8Goebbels' diary is a report of what Hitler said to the 9gaulieter? 10A.
[Mr Irving]
I would say half is. 11Q.
[Mr Justice Gray]
Which half? Half in reported speech and half where he 12repeats exactly the kind of sentence that Hitler had said 13so many times before, but what I will not accept is that 14he necessarily used the word vernichtung, when Hitler 15frequently used other equally vague and ambiguous words 16and indeed euphemisms. I am quite happy to accept that. 17And personally I would consider it deeply shocking if an 18historian was to pin any kind of hypothesis just on this 19third order information which is what this actually is. 20I know it has been done quite recently by Dr Christian 21Gerlach who is a young Hungarian historian. He has tried 22to pin a major hypothesis on it, but he is on the wooden 23path as the Germans says, and the fact that the sentences 24are not in the subjunctive makes it quite plain that 25Goebbels is not reporting what Hitler said. We can ask 26Dr Longerich this on the question of language if I am

. P-146

1right about the subjunctive. 2MR RAMPTON: You will have the opportunity to do that and you 3can ask Professor Evans too whose German is probably as 4good as yours. 5A.
[Mr Irving]
I doubt it but I would prefer to ask Dr Longerich. 6Q.
[Mr Rampton]
He wrote it. Tell me this, is it your belief that Hans 7Frank, Governor General, was a Poland, Eastern Poland, at 8this meeting on 12th December? 9A.
[Mr Irving]
He was a Reichsleiter. This was a speech to the 10Garleiters and the Reichsleiter, so the likelihood is that 11he was present. 12Q.
[Mr Rampton]
And the word "vernichtung" is not really capable of what 13we might call being characterized as a Goebbels' invention 14or exaggeration because it was after all the word that 15Hitler used in his speech in the Reichstager in 1939? 16A.
[Mr Irving]
Yes. 17Q.
[Mr Rampton]
So it would not be the least bit surprising if Hitler had 18used the same word on this occasion, would it? 19A.
[Mr Irving]
Yes. 20Q.
[Mr Rampton]
Why? 21A.
[Mr Irving]
The word "vernichtung" is not killing. It is not 22unambiguously killing. It is destruction. 23Q.
[Mr Rampton]
So you say. You say that. I do not know accept that 24answer? 25A.
[Mr Irving]
It is the primary meaning of the word. 26Q.
[Mr Rampton]
Whether you call it extermination or annihilation, which

. P-147

1are his two primary senses, it is a literal ---- 2A.
[Mr Irving]
Excuse me, extermination was not the primary sense. 3Q.
[Mr Rampton]
No annihilation was? 4A.
[Mr Irving]
It was the third sense. You said extermination or 5annihilation which are its primary senses. Extermination 6is not. It is number 3. 7Q.
[Mr Rampton]
What difference do you see between annihilation and 8extermination? 9A.
[Mr Irving]
Can you read out the three meanings? 10Q.
[Mr Rampton]
No, I ask you in English. What difference do you see? 11A.
[Mr Irving]
I have been annihilated by these books but I have not been 12exterminated. Is that sufficient for you? 13Q.
[Mr Rampton]
Yes, and I annihilate you in cross-examination but I do 14not exterminate you, I hope! Of course I see the 15difference. Seriously, Mr Irving, please, annihilation of 16the Jewish race, come, it is not difficult. German is not 17a mystery language any more than English. What does it 18mean, be honest? 19A.
[Mr Irving]
If Adolf Hitler was considering annihilation to be the 20biological liquidation of the Jewish race, why would he 21have been talking the entire time about the Madagascar? 22Plan. 23Q.
[Mr Rampton]
He talked about the Madagascar plan I think as late as 24sometime in 1942 by which time he had already issued an 25order that the Madagascar plan was to be put to sleep? 26A.
[Mr Irving]
He talked about it on July 24th 1942.

. P-148

1Q.
[Mr Rampton]
Yes, and it was a dead duck? 2A.
[Mr Irving]
This is your word, but why would Hitler talk about even in 3private with his staff? 4Q.
[Mr Rampton]
Because Hitler it would appears, if one reads his table 5talk ---- 6A.
[Mr Irving]
He is talking about it in a conversation with Bormann and 7Himmler, the people who we know were the actual murderers. 8Q.
[Mr Rampton]
It is not to be taken seriously. It cannot be. The Brits 9had occupied Madagascar in May of 1942? 10A.
[Mr Irving]
The British had occupied large parts of the world which 11the Germans subsequently reoccupied. 12Q.
[Mr Rampton]
Like Crete. So your thesis is that Hitler had it in mind 13the German Navy would travel all the way to the East Coast 14of Africa, that huge island, and spend a lot of ships and 15men capturing the island so they could put the Jews on it 16in 1942? 17A.
[Mr Irving]
I know I am not supposed to ask you questions, but you are 18not suggesting that the table talks are fake, are you? 19Q.
[Mr Rampton]
No, no that they are fake, no, far from it. On the 20contrary, the table talks are very good evidence of a man 21who sometimes waffles, sometimes deceives, sometimes talks 22at endless length about nothing very much? 23A.
[Mr Irving]
Rather like counsel in this case! 24Q.
[Mr Rampton]
If you say so. 25MR JUSTICE GRAY: Do not let us let it descend into... 26A.
[Mr Irving]
Mr Rampton -- my Lord, I am not sure if I can say this,

. P-149

1but Mr Rampton rather left the innuendo in the air -- I am 2not sure if you are returning to this -- but I had this 3diary passage in front of me and ignored it when I wrote 4the book. 5MR RAMPTON: Indeed. 6A.
[Mr Irving]
Are you going to state that? 7Q.
[Mr Rampton]
I was going to ask you. You can be personal about it if 8you like, I do not mind, but I am going to ask you whether 9you knew about this at the time you wrote these books. 10A.
[Mr Irving]
Thank you very much indeed. The answer is no. 11Q.
[Mr Rampton]
Why? 12A.
[Mr Irving]
I did not have it. 13Q.
[Mr Rampton]
You did not have it? 14A.
[Mr Irving]
No. This was part of the diaries that were in Moscow. A 15Goebbels', typical Goebbels' diary entry would run to 70 16or 50 or 100 pages. One Goebbels' diary entry in 17September 1943 is 143 pages of typescript for one day. In 18Moscow, we were extremely limited for our time, the days 19we were allowed to view these pages. I did, by chance, 20look at these pages around the German declaration of war 21on the United States as it was a matter of interest. My 22commission from The Sunday Times was to obtain the 23material relating to Germany's declaration of war on the 24United States, obviously for commercial reasons. I read 25those passages, those pages, copied them down. 26MR JUSTICE GRAY: Mr Irving, I just want to make sure I am

. P-150

1understanding what the question is directed to. Are you 2saying that you did not have the passage quoted ---- 3A.
[Mr Irving]
By Longerich. 4Q.
[Mr Justice Gray]
--- in Longerich ---- 5A.
[Mr Irving]
That is correct. 6Q.
[Mr Justice Gray]
--- at page 61, 62, when you wrote Goebbels? 7A.
[Mr Irving]
Indeed, my Lord, yes. I did not have it. It has only 8recently been published by the Institute of History in 9Munich. They obtained the diaries in 1992, shortly after 10I obtained take them, and it has taken them six or seven 11years to make them available to the general public. 12I still have not received the volumes that I ordered from 13the publishers. 14MR RAMPTON: I am not sure what you did have. 15MR JUSTICE GRAY: Can I just pursue this? I am still a little 16bit puzzled. You do make reference though in Goebbels to 17the speech that Hitler made to the Gauleiter? 18A.
[Mr Irving]
Purely because we know that there was a speech from Martin 19Bormann's diary. 20MR RAMPTON: You quote from it? 21A.
[Mr Irving]
And because Goebbels being a typical diarist, he kept on 22rambling back and forth as he dictated the diary to his 23Private Secretary, and he kept on coming back to the 24previous day's speech, but not the passage there. 25MR JUSTICE GRAY: So what are you saying -- just bear with me 26-- I am trying to follow.

. P-151

1MR RAMPTON: I am sorry, my Lord. I will shut up! 2MR JUSTICE GRAY: If I can just speak for a minute? Are you 3saying that what you say about Hitler's speech to the 4Gauleiters in your book, Goebbels, comes from Bormann's 5diary? 6A.
[Mr Irving]
No, my Lord. It comes from a previous passages of the 7Goebbels' diary. Had I read all 100 pages, I would have 8stumbled across this paragraph too; but I can make it very 9easy for your Lordship and for the Defendants by drawing 10their attention to the fact that in my discovery were the 11entire Goebbels' diaries that I obtained from Moscow. 12They could have come to court producing the pages which 13they had found in my discovery, proving that I had had 14them at the time I wrote both Goebbels and Hitler, and 15saying, "Here, he had them here, and yet he ignored them 16when he wrote that", and the answer is they have not done 17so because those pages are not in my documents because 18I did not get them. 19Q.
[Mr Justice Gray]
I am still puzzled. What exactly did you base what you 20write in Goebbels about the Gauleiters speech upon? 21A.
[Mr Irving]
I read the Goebbels' diary for December 13th 1941, just a 22few pages. On each page there would be about 200 pages in 23a big typeface. I read all the pages relating to the 24German declaration of war on the United States which had 25just been made that day; and then Goebbels mentions the 26fact that the previous day Hitler had delivered a speech

. P-152

1to the Gauleiters, and he mentions it in the terms that 2I have quoted in full -- believe me, I quoted everything 3that I had in my hands when I came back from Moscow 4because it was interesting material. Had I read on 5another 30 or 40 pages in the diary for that day, I 6would probably have come across the full length 7description, the report of the Gauleiters' speech on which 8Longerich is relying. But I have not seen it from the 9Moscow day in 1992 to about the middle of last year when 10it was finally made available and quoted by Christian 11Gerlach in his book and elsewhere. I am still not very 12impressed by it, but I do wish to make the point in case 13it was going to be inferred that I had had the material 14and not made use of it. 15MR JUSTICE GRAY: I think I understand. 16A.
[Mr Irving]
It would have been in my discovery and it was not. 17MR RAMPTON: How long are these daily entries in Goebbels' 18diary? I have not understood it. 19A.
[Mr Irving]
They vary in length depending on what is happening. 20Q.
[Mr Rampton]
How long is this entry for 13th December? It reports the 21previous day's events. How long is the entry for the 22speech of Hitler? 23A.
[Mr Irving]
I have no idea. I have not seen it. 24Q.
[Mr Rampton]
Well, you quoted from it. 25A.
[Mr Irving]
The previous entry? 26Q.
[Mr Rampton]
No, you quoted from it on page 383 of Goebbels. This is

. P-153

1what I find baffling. 2A.
[Mr Irving]
Yes, but, you see, he kept on coming back to it, something 3like that he would keep on coming back to as things 4occurred to him. He is sitting in the room with his 5Private Secretary, Dr Richard Otte, his chief 6stenographer, dictating the following morning the events 7of the previous day and he would keep coming back to 8something. The diaries were not really intended for 9publication in that form; they would have been edited. 10I came across an earlier reference to it in the diaries 11which I then have used here; but to this day I have not 12seen any full length description of the Gauleiters' 13speech. 14MR JUSTICE GRAY: How do you know it is 30 or 40 pages further 15on? 16A.
[Mr Irving]
Well, presumably it was because, anyway, it was not on the 17glass plate that I had, my Lord. The glass plate would 18have had 45 pages on it. The glass plate was either five 19times five or six times eight, depending on when it was 20made, pages per glass plate, and they were in complete 21disarray. So I would have had the plate which contained 22the bits I used, but not the bits which contained the 23speech on it. I had no commission from The Sunday Times 24to look into this kind of thing. 25MR RAMPTON: My Lord, may I take some instructions because 26I have just been given a rather important document?

. P-154

1MR JUSTICE GRAY: Do you want to have five minutes? 2MR RAMPTON: Yes, I think I need five minutes actually because 3it is not a document I am not aware of. 4MR JUSTICE GRAY: I think, bearing in mind the transcribers' 5task, but shall we say quarter past? 6(Short Adjournment) 7MR RAMPTON: I am grateful to your Lordship. Can I say this? 8I will say it to Mr Irving, if I may? Mr Irving, I say 9two things now and I undertake to come back to it on 10Monday, not more this afternoon because I am not clued up 11enough yet, but I will be. First, I do not accept that 12the failure to use a subjunctive is necessarily a bar to 13the written material being a report of what somebody else 14says in German. You do not have to comment on this. 15I tell you this so that you will know what is coming. 16Second, that the Goebbels' diary entry which you quoted in 17the book is not as long as you said that it was. All 18right? 19A.
[Mr Irving]
I am sorry. I do not understand the second part of that, 20the Goebbels' diary entry which I quoted? The original 21entry you mean? 22Q.
[Mr Rampton]
Yes. 23A.
[Mr Irving]
The original entry from which I quoted. 24Q.
[Mr Rampton]
I do not know because I have not looked at your 25discovery. That is one of the things I want to do, is how 26long is the entry from which you quoted. I also want to

. P-155

1find out for certain what proportion of that bears to the 2whole of the entry? 3A.
[Mr Irving]
Can I suggest, therefore, that when we resume on Monday 4I bring the entire December 1941 Goebbels' Diary that 5I brought back from Moscow with me and can see what I had 6and what I did not because it was in the discovery and you 7must have seen. 8Q.
[Mr Rampton]
I have not seen it, but I am sure we must have it. 9A.
[Mr Irving]
Well, if you did not see it, it is not my fault. It was 10in your discovery and it was available. 11Q.
[Mr Rampton]
I am not criticising you, Mr Irving. I am quite happy to 12take blame for negligence, idleness, whatever you like. 13 Mr Irving, I want, therefore, to pass away from 14that, if I may, and, if his Lordship will allow me, to 15come back to it on Monday when I have done my homework and 16ask you about something else, which, as you said, it is 17probable that Hans Frank as one of the Reichleiters? 18A.
[Mr Irving]
He was ---- 19Q.
[Mr Rampton]
He was General ---- 20A.
[Mr Irving]
--- he was a Reichleiter and he would have been of the 21rank to attend that meeting. 22Q.
[Mr Rampton]
Surely he would; he was General Governor, was he not? 23A.
[Mr Irving]
Yes. In fact, he went to Berlin for the meeting, so there 24is no reason to dispute he was there. 25Q.
[Mr Rampton]
The odious (and it is not really meant to be a pun) 26Globocnik was one of his subordinates?

. P-156

1A.
[Mr Irving]
Of Hans Frank? At this time he was the Police Chief in 2Lublin, I believe. 3Q.
[Mr Rampton]
Yes. 4A.
[Mr Irving]
Yes -- no, this is not true. The SS was -- they conducted 5an independent existence in the Government General. 6Q.
[Mr Rampton]
Right, OK. It does not matter. It is not important. 7A.
[Mr Irving]
Do you wish me to expand on that? 8Q.
[Mr Rampton]
No, not now. 9A.
[Mr Irving]
No? There was no hierarchy bringing the two together. 10The name is Globocnik -- G-L-O-B-O-C-N-I-K. 11MR RAMPTON: Odilo Globocnik. 12MR JUSTICE GRAY: I think the surname will suffice. 13MR RAMPTON: Otherwise known as "Globos". May Mr Irving please 14be provided please with Professor Browning's report? 15A.
[Mr Irving]
Have we finished with Dr Goebbels? 16Q.
[Mr Rampton]
I have finished with that for the moment. As I say, I am 17coming back to that later on. I am trying to keep some 18semblance of chronological order. I am still in December 191941. Have you got Dr Browning there? 20A.
[Mr Irving]
Page 30 and 31? 21Q.
[Mr Rampton]
30 and 31, correct. Dr Browning also quotes the speech of 22Hitler, but in abbreviated form, in other words, he does 23not quote as much of the Goebbels' diary entry as does 24Dr Longerich. 25A.
[Mr Irving]
Yes. 26Q.
[Mr Rampton]
Do you see that?

. P-157

1A.
[Mr Irving]
Yes. 2Q.
[Mr Rampton]
He goes down as far as saying (which you agree is a 3correct translation, well, I do not know if you do), that 4was no figure of speech, top of 31, "The World War is 5here. The Vernichtung", whether it is destruction, 6extermination, annihilation or whatever, "of the Jews must 7be the inevitable consequence". 8A.
[Mr Irving]
Well, that is again a contentious and tendentious 9translation. 10MR JUSTICE GRAY: Well, we have been through that I think 11sufficiently. 12MR RAMPTON: We have been through that. That is why I used the 13word "vernichtung"? 14A.
[Mr Irving]
Well, but it is the word "Jews" also that we have to look 15at there, is it not? Destruction of the Jews. But this 16is ---- 17MR JUSTICE GRAY: That is quite plain because he refers to "des 18Judens", so there really cannot be any argument about 19that, can there? 20A.
[Mr Irving]
No. "[German].. Judentums", no. 21Q.
[Mr Justice Gray]
There is not reference to "Judentums". 22A.
[Mr Irving]
It is the fifth line, so he has allowed himself a lot of 23poetic licence in his translation. My Lord, I have to be 24careful about what I accept here I cannot be heard to 25accept something that is not ... 26Q.
[Mr Justice Gray]
You are quite right. I think I was wrong. You are quite

. P-158

1right? 2MR RAMPTON: You were in that respect, my Lord, but not, in 3fact, in the earlier part of which forms the 4context. "Zeeda ... [German] ... Vuren" and "ihre" there 5is "their" which is the Jews' is it not? 6MR JUSTICE GRAY: But in connection with "Vernichtung", it is 7"Judentum". 8MR RAMPTON: Both have "vernichtung" attached to them. 9A.
[Mr Irving]
But I believe it is the next part you wish to continue 10with. 11Q.
[Mr Rampton]
It is the next part. It is what Hans frank is reported as 12having said when he got back to the General Government on 1316th December 1941. This is printed in what one might 14call the official common place book, would it be right? 15It is the Tagesbuch. That is an official record, is it 16not, of some kind? 17A.
[Mr Irving]
It is the abridged version of the multi-volumed diaries 18and conference records of the General Governor, Hans 19Frank. 20Q.
[Mr Rampton]
And you have used it yourself? 21A.
[Mr Irving]
I used the original manuscript, yes. I did not use the 22printed edition. It is in my discovery. 23Q.
[Mr Rampton]
You have used this passage? 24A.
[Mr Irving]
I have indeed and I used the original manuscript and not 25the printed version. 26Q.
[Mr Rampton]
Maybe so. At the end of this first page, 31, in

. P-159

1translation, perhaps here the German does not really 2matter, perhaps you will agree. The first complete 3paragraph at the bottom of -- sorry, last paragraph on the 4page: "What is to happen to the Jews? Do you believe 5that they will be lodged in settlements in Osland?" That 6is the Baltic countries, is it not, Osland? 7A.
[Mr Irving]
Yes. 8Q.
[Mr Rampton]
"In Berlin we were told, 'Why all this trouble? We cannot 9use them in the Osland or the Reichcommissariat either. 10Liquidate them yourselves!'". 11 Then goes on, apparently, Governor Frank: "We 12must destroy the Jews wherever we encounter them and 13wherever it is possible in order to preserve the entire 14structure of the Reich". I would ask you to turn over the 15page, Mr Irving, where at the bottom of page 32 you will 16find the German of ---- 17A.
[Mr Irving]
That is what I have just been reading, yes. 18Q.
[Mr Rampton]
Yes. Has Professor Browning translated it correctly? 19A.
[Mr Irving]
Yes. I used a different translation in my own book, but 20this is an adequate translation. 21Q.
[Mr Rampton]
That is right, is it not? 22A.
[Mr Irving]
Yes. 23Q.
[Mr Rampton]
But he has not translated the last two lines on page 32. 24Would you please read those and tell us what they mean? 25A.
[Mr Irving]
Well, it is an incomplete fragment. 26Q.
[Mr Rampton]
He has put an ellipsis?

. P-160

1A.
[Mr Irving]
He has put what? 2Q.
[Mr Rampton]
He has put an ellipsis in, has he not, to show that ---- 3A.
[Mr Irving]
Yes, but it is the second half of a sentence and, as you 4know, in German, the Germans put their verbs at the end, 5so it... 6Q.
[Mr Rampton]
Yes. Be kind enough just to translate what we have. 7A.
[Mr Irving]
"But if we then undertake incursions which in some way 8lead to a destructive result or success and, indeed, in 9connection with the measure -- in connection with the 10great measure which is to be conferred upon at the Reich" 11-- this is a reference to the coming Bunzig conference, 12presumably. 13Q.
[Mr Rampton]
That is right. 14A.
[Mr Irving]
It is a truncated sentence it is difficult to find your 15way into without the beginning. "Vernichtungs Erfolg" is 16the word you want to see. V-E-R-N-I-C-H-T-U-N-G-S 17E-R-F-O-L-G. 18Q.
[Mr Rampton]
Does it mean this, Mr Irving, at any rate the last part of 19that first of the two bottom lines: "It will anyway come 20to a complete or successful destruction", "Vernichtungs 21Erfolg"? 22A.
[Mr Irving]
That would be a rigid and unacceptable translation. 23I would say, "If we succeed in wiping them out". 24MR JUSTICE GRAY: Which does "Erfolg" mean? 25A.
[Mr Irving]
"Success", "If we succeed in wiping them out", 26"Vernichtung" or "If we succeed in destroying them".

. P-161

1MR RAMPTON: A successful wiping out? 2A.
[Mr Irving]
A successful wipe out, yes, but German sentences you 3frequently have to break up and recast in order to make 4them acceptable. 5Q.
[Mr Rampton]
I am not playing tricks. I will try to find the whole of 6that. 7A.
[Mr Irving]
I am trying to help you, Mr Rampton. 8Q.
[Mr Rampton]
I am being passed ---- 9MR JUSTICE GRAY: Can I just be clear? Are you accepting that 10what Hans Frank is recording here is what Hitler said in 11Berlin to the Gauleiter? 12A.
[Mr Irving]
Yes -- no, he has not made a reference to the Gauleiters 13specifically. 14Q.
[Mr Rampton]
I know he has not made a reference to it ---- 15A.
[Mr Irving]
No. 16Q.
[Mr Justice Gray]
--- but he says: "In Berlin we were told", and I rather 17inferred that Mr Rampton was suggesting that that was from 18Hitler's speech to the Gauleiter? 19A.
[Mr Irving]
I think it would be quite a dangerous leap to make. 20Q.
[Mr Justice Gray]
Am I wrong about that? 21A.
[Mr Irving]
It is put in ---- 22MR RAMPTON: No, it is not quite what I had put because I do 23not have the evidence to make that kind of suggestion. 24I am suggesting that while Hans frank was in Berlin, 25somebody told him, and he was there probably amongst other 26reasons for the occasion of Hitler's speech ----

. P-162

1A.
[Mr Irving]
Yes. 2Q.
[Mr Rampton]
-- somebody told him, it might have been Hitler, it might 3have been Heydrich, that they have to see to the 4liquidation of the Jews themselves in the East. That does 5mean that, does it not? 6A.
[Mr Irving]
I do not think the word they use is "liquidation". He 7says "wipe out", "If we have a success in wiping them out, 8destroying them", "Vernichtung", which can done in a 9number of ways as I gave the instance with Christianity or 10with drug addiction. 11Q.
[Mr Rampton]
I am not sure you are right about that. The word is 12"liquidiet zi selbe"? 13A.
[Mr Irving]
I am sorry, I was looking at the wrong part. 14Q.
[Mr Rampton]
No the quote is: "Man hut uns in Berlin gesagt", "We were 15told in Berlin"? 16A.
[Mr Irving]
Oh, unquestionably, yes. 17Q.
[Mr Rampton]
"Liquidate them yourselves"? 18A.
[Mr Irving]
Yes. 19Q.
[Mr Rampton]
So ---- 20A.
[Mr Irving]
And the reason that Browning knows about this is because 21he found this quotation in my books. I am the first one 22to have dug it out. 23Q.
[Mr Rampton]
Brownie points to you, Mr Irving, but the fact is that 24Hans Frank is saying on this occasion when he gets back to 25Poland -- I think this took place in Krakow, did it not? 26A.
[Mr Irving]
His headquarters is in Krakow, yes.

. P-163

1Q.
[Mr Rampton]
He is saying: "When we were in Berlin" ---- 2A.
[Mr Irving]
"They told us". 3Q.
[Mr Rampton]
--- "they told us, 'We can't solve the Jewish problem for 4you. We can't house them. Liquidate them yourselves"? 5A.
[Mr Irving]
Yes. Berlin, of course, was the seat of the 6Reichssicherheits Hauptamt, of Reinhardt Heydrich. 7Q.
[Mr Rampton]
I know, that is Heydrich's headquarters too. 8A.
[Mr Irving]
Hitler's headquarters, well, in East Prussia, not in 9Berlin. 10Q.
[Mr Rampton]
Certainly it is though, whether Hitler took part in those 11discussions or not, I cannot tell you. I do not propose 12that he did. I do not ---- 13A.
[Mr Irving]
I think it is a very interesting fragment, a verbatim 14transcript to which one can attach a great deal of 15importance rather than reported third person subjunctive, 16non-subjunctive stuff. This is Hans Frank's actual words 17taken down by a stenographer and that is why I was very 18pleased to quote them in full. 19Q.
[Mr Rampton]
Yes, surely. We are not here necessarily, Mr Irving, 20talking about the Jews that the Einsatzgruppen found in 21Russia; rather the contrary, do you not think? 22A.
[Mr Irving]
The German Jews. 23Q.
[Mr Rampton]
We are talking about two groups of Jews if we are talking 24about Hans Frank and the General Government? 25A.
[Mr Irving]
Yes. 26Q.
[Mr Rampton]
We are talking about German and other Jews, Slavakia or

. P-164

1wherever else, French, Dutch, Belgium and so on, that were 2shipped to East, transported I mean, but we are also 3talking about the indigenous Jews at Poland, are we not? 4A.
[Mr Irving]
Primarily at this time the indigenous Jews. I do not 5think that any major shipment of Jews had started from 6Western Europe in Poland or the General Government at this 7time. 8Q.
[Mr Rampton]
Do you agree that Eichmann said at the Bunzig conference, 9I think it was he, it may have been somebody else, it may 10have been somebody else who gave the figure, there were 11roughly two and quarter, two and a half million Jews 12living in Poland at that time in early 1942? 13A.
[Mr Irving]
That is almost certainly the right figure, but Eichmann 14did not speak at the Bunzig conference. He just kept the 15minutes as I understand it. 16Q.
[Mr Rampton]
But that is the figure that was given at the Bunzig 17conference? 18A.
[Mr Irving]
I will take your word for it, Mr Rampton. 19Q.
[Mr Rampton]
You have read it. I am sure you have read the protocal, 20the minute or whatever it is. So what Hans Frank is 21saying here is: "The Jews that we are responsible for 22(getting rid of) numbering roughly two and a quarter 23million, we have been told by Berlin we have to liquidate 24ourselves". That is what it is saying, is it not? 25A.
[Mr Irving]
No. What he is saying is: "Do not start dumping Jews on 26us. We have got no room for the ones we have got. Solve

. P-165

1your own problems". 2Q.
[Mr Rampton]
No, "in Berlin we were told"? 3A.
[Mr Irving]
Yes. 4Q.
[Mr Rampton]
Not, "I said to the people in Berlin"? 5A.
[Mr Irving]
Yes. 6Q.
[Mr Rampton]
"Man hat" is passive? 7A.
[Mr Irving]
Yes. 8Q.
[Mr Rampton]
"Uns gesagt" means "they told us in Berlin"? 9A.
[Mr Irving]
"Why all this bother? Why all this fuss and bother?" 10Q.
[Mr Rampton]
That is right. 11A.
[Mr Irving]
They are talking about what they are going to be doing 12with the Jews that people are talking about now tossing 13out of Western Europe, and Hans Frank has been fighting 14hand and foot at having any dumped in his domain. 15Q.
[Mr Rampton]
Yes. He has been told he has got to do it himself? 16A.
[Mr Irving]
No, he has been you take what you are given. He is 17saying, "I don't want them." I know the background to 18this story, Mr Rampton. 19Q.
[Mr Rampton]
What do the words mean, I am sorry, Mr Irving, I thought 20you had agreed this was an accurate translation? 21A.
[Mr Irving]
It is accurate. 22Q.
[Mr Rampton]
"In Berlin we were told, 'Why all this trouble? We cannot 23use them in the Osterland or Reichskomissariat either. 24Liquidate them yourselves.'"? 25A.
[Mr Irving]
No. No one is talking about shipping Jews from the 26Osterland or the Ukraine into Berlin. The shipment is

. P-166

1going other way round. 2MR JUSTICE GRAY: What Mr Rampton is putting to you is that 3that phrase "liquidate them yourselves" is in effect a 4direction from Berlin to the General Government. 5A.
[Mr Irving]
No, sir. I read it differently both in the original and 6even now. This is Hans Frank recalling what he told the 7Berliners saying, "Stop dumping your Jews on us, you solve 8your own problems, you liquidate them yourselves". 9MR RAMPTON: I am going to refer you to the full text of what 10Hans Frank said in a moment. Can you first of all read 11your own version of this, please, on page 428 of Hitler's 12War 1991. 13A.
[Mr Irving]
Can we look at it in the earlier version because it is 14totally unchanged? 15Q.
[Mr Rampton]
No, it is not in the earlier version so far as I know. 16A.
[Mr Irving]
It definitely it is. It is in every book that I have 17written. Which page, Mr Rampton? 18Q.
[Mr Rampton]
If you want the earlier version, I am not sure it is in 19the earlier version, but I will check that. Yes, it is. 20If you want to use the earlier version, first, I have no 21problem with that. Page 332. 22A.
[Mr Irving]
Yes, "Yet the blood purge continued". 23Q.
[Mr Rampton]
Yes. I am waiting for his Lordship's file to emerge. 24MR JUSTICE GRAY: Hitler's War. 25MR RAMPTON: It is 1977 Hitler's War, my Lord, I think the 26first volume.

. P-167

1MR RAMPTON: It is I think more or less identical to what is in 2the 1991 edition. 3MR JUSTICE GRAY: Have you got a reference for that? 4MR RAMPTON: Yes, that is page 427 it starts, the last large 5paragraph, the last three lines. I will read. It 6immediately follows the reference to the Himmler telephone 7note of 1st December. Mr Irving writes: "Yet the blood 8purge continued". 9A.
[Mr Irving]
Shall I read it? It is my book. 10Q.
[Mr Rampton]
No, Mr Irving. No, I will read it: "Yet the blood purge 11continued. The extermination programme had gained a 12momentum of its own. Hans Frank announcing to his Lublin 13Cabinet on December 16th 1941, that Heydrich was calling a 14big conference in January on the expulsion of Europe's 15Jews to the East, irritably exclaimed: Do you imagine 16they are going to be housed in neat estates in the Baltic 17provinces! In Berlin' - and with Hitler in East Prussia 18this can only be taken as a reference to Heydrich's 19agencies -" -- I am coming back to that -- "they tell us", 20they, the people in Berlin, "tell us", the people in 21charge in the General Government: Why the caviling? 22We've got no use for them either ... liquidate them 23yourselves!" The "yourselves" are the people in Poland? 24A.
[Mr Irving]
Yes. Well, no, not necessarily. Of course I would just 25like to comment. That is an odd passage for a Holocaust 26denier to put into a book, is it not, this entire passage;

. P-168

1somebody who is allegedly denying the Holocaust he puts in 2this extraordinary passage? 3Q.
[Mr Rampton]
It is there, is it not? 4A.
[Mr Irving]
It is indeed, and I am accused of being a Holocaust 5denier. 6Q.
[Mr Rampton]
Maybe. Mr Irving, the true sense of that is that Hans 7Frank was told while he was in Berlin that it was his 8problem how to liquidate Poland's two or three million 9Jews, is it not? 10A.
[Mr Irving]
Mr Rampton, I am sure you have read any number of 11transcripts of verbatim conferences. Hans Frank is quite 12clearly not speaking from a prepared script. He is 13addressing a meeting, his mind darting here and there. He 14is giving snatches of what he was told in Berlin by them. 15He is giving snatches of what his retort was. He is not 16telling the stenographer, "close quotes, open quotes, 17close quotes again", and the stenographer is taking it 18down as it said. 19MR JUSTICE GRAY: That may be, but you would have to accept, 20would you not, that the way you have recorded this in 21Hitler's War is that Frank was talking about what Berlin 22had told him and the General Government? 23A.
[Mr Irving]
I cannot say, my Lord. I do not know who what is talking 24to whom in that final three words, "liquidate them 25yourselves". It is not evident on the transcript either. 26So I have left it, I saw no reason to be specific in my

. P-169

1book as to who was talking to whom. I would have 2introduced probably an ambiguity one way or the other. So 3I left it just as it was in the transcript which I thought 4was the most accurate thing I could do. We do not know if 5it is Poland talking to Berlin or Berlin talking to 6Poland. 7Q.
[Mr Justice Gray]
But if you are disassociating Hitler from what is said, as 8you plainly are, does that not indicate that you must be 9seeking to conveying to readers that the instructions are 10coming from Berlin? 11A.
[Mr Irving]
It is unimportant to me, my Lord, which way those 12instructions are coming. It is coming all at the same 13level. Berlin is shrieking at Krakow and Krakow is 14shrieking at Berlin, and Hitler is somewhere else. This 15is a biography of Adolf Hitler. It is not a book about 16the Holocaust. 17Q.
[Mr Justice Gray]
If there were instructions going from Krakov to Berlin 18there would be no point in disassociating Hitler from it? 19A.
[Mr Irving]
Hitler was not in Berlin, my Lord. Hitler at this time, 20December 16th, was in his headquarters in East Prussia. 21Q.
[Mr Justice Gray]
I think you understand the question. 22A.
[Mr Irving]
That is the point I make. 23MR RAMPTON: Mr Irving, that simply will not do. In Berlin you 24break off to parenthesize, if I can invent that word, "and 25with Hitler in East Prussia this can only be taken as a 26reference to Heydrich's agencies (in Berlin)"?

. P-170

1A.
[Mr Irving]
Yes. 2Q.
[Mr Rampton]
"They" Heydrich's agencies "tell us: Why the caviling? 3We" in Berlin "have no use for them either. Liquidate 4them yourselves", you, the people in Poland? 5A.
[Mr Irving]
These are your interpolations you are putting in of 6course. 7Q.
[Mr Rampton]
No, I am reading your words, Mr Irving? 8A.
[Mr Irving]
No, I did not put in those interpolations. 9Q.
[Mr Rampton]
That is what it means though, is it not? 10A.
[Mr Irving]
That is what you submit. 11Q.
[Mr Rampton]
Do you disagree? 12A.
[Mr Irving]
I rest entirely on the way that I quote this very 13ambiguous fragment of stenographic text without making any 14interpolations one way or the other. As I explained in 15the Hitler biography, I did not consider it to be 16necessary really to point out or to try to work out who 17was talking to whom. I found it such an 18extraordinary ---- 19MR JUSTICE GRAY: So your evidence is, I am sorry to interrupt 20you, that this is capable at any rate of meaning that 21Krakov was telling Heydrich in Berlin "liquidate them 22yourselves", that is your evidence? 23A.
[Mr Irving]
This is the far more logical interpretation, because 24I know from all the other documents at this time that Hans 25Frank was hysterical at the mention that train loads of 26Jews would be sent to the Governor General where he had

. P-171

1problems housing and feeding people anyway, and he was 2saying to Berlin: "Stop trying to shift your problems 3into Poland. We are not just a dumping ground for your 4Jews." This comes up in very many of the conferences at 5that time. There is one particular record I remember 6taking by Martin Bormann in October 1941, and that 7emboldens me in putting the alternative interpretation, 8the alternative arrow direction, shall we say, on that 9final three words, but rather than get involved in that 10rather irrelevant discussion in this book which is about 11Hitler, I just left this extraordinary fragment of 12stenographic record, this transcript, as it is, because it 13is so pregnant with hatred and brutality and total 14callousness towards human life, and it indicates the kind 15of level at which these decisions were taken and the kind 16of gormless mentality of the people who took these 17decisions who were later quite rightly hanged for it. 18MR RAMPTON: My Lord, I am not going to push that particular 19point any further. I am going to come back, perhaps not 20today, to the full text of what Hans Frank said for 21context. I am getting some clever people to translate it 22as I speak. 23A.
[Mr Irving]
Mr Rampton, can I then in that case bring on Monday the 24text I have, which may or not be identical with the text 25that you have. 26Q.
[Mr Rampton]
I think you certainly should.

. P-172

1A.
[Mr Irving]
It may be shorter or longer. This is the reason why I say 2it. 3Q.
[Mr Rampton]
You certainly should. 4A.
[Mr Irving]
I have the pages in the original photocopy. 5Q.
[Mr Rampton]
That is absolutely fine. Bring whatever you like you feel 6you need to defend yourself with. It is right, is it not, 7that having written both in 1977, as I say if you want to 8check it, on pages 427, 428 of 1991 Hitler's War, which 9I think is identical ---- 10A.
[Mr Irving]
Yes. 11Q.
[Mr Rampton]
--- having written "man hat uns gesagt" or "in Berlin" and 12then a quote, on page 386 of Goebbels you write this. 13A.
[Mr Irving]
Yes. 14Q.
[Mr Rampton]
I will read it out: "Hans Frank's Government General was 15flatly refusing to accept any more", Jews that is. "Frank 16had exclaimed irritably at one of his cabinet meetings in 17Krakov that Berlin was telling them they got no use for 18the Jews either, 'liquidate them yourselves', was his, 19that is Frank's, retort? 20A.
[Mr Irving]
Yes. 21Q.
[Mr Rampton]
I notice, and perhaps you did too, as I read that there is 22no reference there to Heydrich's agencies or to Hitler 23being absent, is there? 24A.
[Mr Irving]
We are talking about Berlin and we are talking about Frank 25retorting. Having now advanced something like ten years 26down the road of research and read a very large number of

. P-173

1further documents relating to this particular context and 2these questions, I am that much more certain that the 3arrow goes from East to West rather than from West to East 4as far as those three words are concerned. 5Q.
[Mr Rampton]
Be honest, Mr Irving, in Hitler's War ---- 6A.
[Mr Irving]
Excuse me, I am speaking here on oath, I am being honest. 7Q.
[Mr Rampton]
I do not believe you are. In Hitler's War the arrow went 8firmly from West to East. You changed the account for 9Goebbels, did you not? That is why there is no reference 10to Hitler or to Heydrich in this text? 11A.
[Mr Irving]
I do not accept that contention at all. In Hitler's War 12I gave the transcription exactly as it occurs in the 13records and I left it for the reader to make up their own 14mind. Here I am that much more certain which way the 15arrow went. 16Q.
[Mr Rampton]
Why did you insert in Hitler's War the parenthesis "and 17with Hitler in East Prussia this can only be taken as a 18reference to Heydrich's agencies"? 19A.
[Mr Irving]
This is like an obiter from on high where the judge says 20to the jury, "I think that you need to take account of 21this but of course make up your own mind", and where you 22are telling the reader, well, make up your own mind, here 23is what is what the transcript says, but just in case you 24have forget it, Adolf Hitler lives in East Prussia and he 25is not in Berlin on the day this speech is being made. 26Q.
[Mr Rampton]
He was not in Berlin on 16th December 1941, Mr Irving?

. P-174

1A.
[Mr Irving]
Yes. 2Q.
[Mr Rampton]
Because on 16th December 1941 he went to the Wolf's lair, 3did he not? 4A.
[Mr Irving]
He was certainly, at the time that Frank was speaking here 5Hitler was back in East Prussia. 6Q.
[Mr Rampton]
On page 383 ---- 7A.
[Mr Irving]
May I also say that if he was referring to Hitler by the 8use of the word "man", which is the equivalent of the 9French "on". 10Q.
[Mr Rampton]
I did not say that. 11A.
[Mr Irving]
If he was referring to Hitler then he would have said, "at 12the very highest level we have been told". He would not 13have used the rather offensive "man". 14Q.
[Mr Rampton]
"On" in French, I do not know any German but I have quite 15good French, Mr Irving, "on" in French is not the least 16bit offensive. It is merely a form of expressing a 17passive sense. 18A.
[Mr Irving]
Yes, but he would have been specific. He would have said 19"uns getstella(?)" or [German spoken] but more likely 20"uns getstella(?)" at the highest level. 21Q.
[Mr Rampton]
According to your first version, "Heydrich's agencies". 22A.
[Mr Irving]
Had he wished to refer to Hitler by that, yes. 23Q.
[Mr Rampton]
To what? 24A.
[Mr Irving]
If by the use of the word "man" in Berlin he would not 25have used the very impersonal version of saying "man". 26Q.
[Mr Rampton]
Anyway, you have got Hitler away from whatever Frank was

. P-175

1told because you have got him in East Prussia? 2A.
[Mr Irving]
Continue, yes. 3Q.
[Mr Rampton]
Yes. In fact he did not go to the Wolf's lair until 16th 4December, did he? 5A.
[Mr Irving]
He probably left Berlin on the night of the 15th, took the 6overnight train back to East Prussia. I could tell you 7from the Hitler's War, the headquarters' war diary which 8I have in the blue volume there. 9Q.
[Mr Rampton]
All I can tell you is that in Goebbels Mastermind of the 10Third Reich on page 383 you write this: "Returning by 11train on December 16th to the Wolf's lair"? 12A.
[Mr Irving]
Yes. 13Q.
[Mr Rampton]
"Hitler dictated a famous order", something like that? 14A.
[Mr Irving]
Yes, but I can tell you whether he left Berlin on the 15night of the 15th or not. 16Q.
[Mr Rampton]
So he was in Berlin when Hans Frank was in Berlin 17receiving this instruction? 18A.
[Mr Irving]
You are now referring to 12th December? 19Q.
[Mr Rampton]
Whenever. He did not leave Berlin until the night of the 2015th or the morning of the 16th. Hans Frank has got to go 21further. He has got to go all the way back to Krakov 22which is further than East Prussia? 23A.
[Mr Irving]
I am sorry to admit I am now totally at sea. Which times 24in Berlin are we talking about? 25Q.
[Mr Rampton]
Hans Frank is reporting what he was told in Berlin. When 26he was ----

. P-176

1A.
[Mr Irving]
Yes, by somebody whom we have not identified. 2Q.
[Mr Rampton]
Maybe, but Hitler was in Berlin at that time? 3A.
[Mr Irving]
He was in Berlin on, well, he was in Berlin on the 12th, 413th and 14th definitely. 5Q.
[Mr Rampton]
Yes, and probably on the 15th as well? 6A.
[Mr Irving]
Yes, but we do not know if he is referring to Hitler. He 7says "man". "We have been told in Berlin". Berlin's 8population is two million. 9Q.
[Mr Rampton]
I wish you would not make speeches, Mr Irving, but listen 10to my questions. Why was it relevant to observe, if it is 11perfectly certain or more or less certain or as certain as 12an historian would like, that Frank and Hitler were in 13Berlin at the same time, why do you say "in Berlin" close 14quotes, " - and with Hitler in East Prussia this", that is 15to say Berlin, "can only be taken as a reference to 16Heydrich's agencies"? 17A.
[Mr Irving]
In Berlin people tell us -- had it been Adolf Hitler who 18had told him this, he would not have said the slightly 19depricating "in Berlin people tell us", certainly not in 20the company of Reichsministers and Reichsleiters. 21Somebody would have reported back. 22MR JUSTICE GRAY: You are slightly at cross purposes. I think 23all that Mr Rampton is putting at the moment is that they 24were in Berlin at the same time? 25A.
[Mr Irving]
This I accept. 26Q.
[Mr Justice Gray]
Namely, Frank and Hitler.

. P-177

1A.
[Mr Irving]
This I accept. 2Q.
[Mr Justice Gray]
So your point on "man" and whether that is significant is 3a different point. 4A.
[Mr Irving]
Perhaps I am jumping the gun on that, yes. 5MR RAMPTON: You are. You are not seeing, whether deliberately 6or not I know not, you are not seeing what I am putting to 7you. What I am putting to you, and I will put it 8directly, although I would have thought it was pretty 9obvious, is that with this little phrase in Hitler's War 10both editions and with Hitler in East Prussia, this can 11only be taken as a reference to Heydrich's agency, 12"continue, they tell us", etc., "to liquidate them 13yourselves". By doing that what are you actually telling 14the reader is that Hitler was not in Berlin at the time 15when Hans Frank was given this instruction? 16A.
[Mr Irving]
I think probably the parenthesis should have been shifted 17forward two or three words to include "also people tell 18us", "in Berlin people tell us", so that i makes it quite 19plain that I am relying on the parenthesis both on the "in 20Berlin" and the rather depricatory world "people tell us". 21MR JUSTICE GRAY: That is not quite an answer to the question. 22MR RAMPTON: It is not. 23A.
[Mr Irving]
Very well. Yes, I will accept the point which you make, 24yes. 25MR RAMPTON: Had you sought historical accuracy, that 26parenthesis would have been attached to December 16th

. P-178

11941, would it not, at the top of the page: "Announcing 2to his Lublin cabinet on December 16th 1941 Hitler was in 3East Prussia at the time", if it was of any interest to 4anybody. What you have tried to do, you have distorted 5the chronology in order to make perfectly certain that 6Hitler cannot have anything to do with this appalling 7instruction to Hans Frank? 8A.
[Mr Irving]
I have not distorted any chronology at all. The dates are 9perfectly certain. On December 16th, at the time of this 10speech by Governor Frank to his cabinet, Hitler is in the 11Wolf's lair in East Prussia, as I said. 12Q.
[Mr Rampton]
Mr Irving, perhaps you are tired, perhaps I am tired. 13A.
[Mr Irving]
I am not so tired that I do not remember dates that I have 14written in books. 15Q.
[Mr Rampton]
Mr Irving, I am sorry, it is not the problem that you do 16not remember the dates. I am afraid I think you remember 17them only too well. I will try once again then and I am 18going to leave it. Why do you not have the text of 19Hitler's War in front of you? 20A.
[Mr Irving]
I have it open, yes. 21Q.
[Mr Rampton]
428, it does not matter which edition: "Hans Frank 22announcing to his Lublin cabinet on December 16th 1941 23that Heydrich was calling a big conference in January on 24the expulsion of Europe's Jews to the East, irritably 25exclaimed", blah-blah-blah "! 'In Berlin' and with Hitler 26in East Prussia, this can only be taken as a reference to

. P-179

1Heydrich's agencies", blah-blah-blah, "liquidate them 2yourselves." 3A.
[Mr Irving]
Yes. 4Q.
[Mr Rampton]
Now that is apt to suggest to any person who is even 5marginally literate that Hitler was not in Berlin at the 6time when Hans Frank was and was given that instruction? 7MR JUSTICE GRAY: You have got a "yes" to that already, Mr 8Rampton. 9MR RAMPTON: I have, have I? 10A.
[Mr Irving]
I fully understand the point you are trying to make and 11that is a narrow interpretation of those words which you 12are trying t slant or guy rope in the direction you want 13them. The point I am making is that Hitler's headquarters 14is historically in East Prussia. The seat of the 15Reichssicherheitshauptamt under the SS is in Berlin, and 16Governor Frank making his speech is in Krakow. When he 17talks about Berlin he is talking about the SS. When he 18wants to talk about Hitler he will say "East Prussia". 19When he says, "in Berlin they tell us this or tell us 20that", he is not talking about a specific meeting or a 21specific event where they have been given these 22instructions. He is just talking about these block heads, 23these mutton heads in Berlin who imagine that life can be 24made so easy that they just put the people on trains and 25send them to Poland. 26Q.
[Mr Rampton]
Yes, Mr Irving. Then why insert the reference to Hitler

. P-180

1at all in relation to what Frank was told in Berlin? 2A.
[Mr Irving]
Because I was trying to put into one terse line of text 3given the constraints of writing a book that is going to 4be less than 1,000 pages what I just set out to you in 5probably ten lines of text. 6Q.
[Mr Rampton]
Why? What has Hitler got to do with this? 7A.
[Mr Irving]
This is his Hitler's biography. This is about Adolf 8Hitler. 9Q.
[Mr Rampton]
Unless there is evidence that Hitler said this to Frank 10himself, you would not bother even to mention Hitler? 11A.
[Mr Irving]
It may be that ignorant people will assume that because 12Adolf Hitler is the Reichschancellor and his capital is 13Berlin, therefore, the reference to "people" is Adolf 14Hitler. I am trying to make sure that ignorant people do 15not draw the wrong reference. 16Q.
[Mr Rampton]
In order that ignorant people should not have to have it 17explained why it is not likely this order came from 18Hitler, I beg to differ with you about that, but in order 19that ignorant people, as you call them, should have that 20explained to them neatly, you actually tell a neat little 21fib. You get Hitler out of Berlin when in fact he was 22there? 23A.
[Mr Irving]
But there is nothing that is the least bit wrong about the 24sentence I put in there. With Hitler in East Prussia, his 25headquarters were in East Prussia, the references to 26Berlin can only be taken as references to the SS, the

. P-181

1Heydrich's agencies, who were in fact wholly responsible 2for these operations. As we know from other sources, 3Hitler was intervening constantly to stop these things 4being done. 5MR JUSTICE GRAY: I have got the point anyway. 6MR RAMPTON: Yes, I am not going on. 7A.
[Mr Irving]
It is the reference to general geography; not to specific 8meetings or conferences that you have only recently heard 9about, no matter how dramatic these discoveries may be or 10made to seem. 11Q.
[Mr Rampton]
Will your Lordship forgive me a moment? May Mr Irving 12please be given bundle H3 (ii). I think these are 13Professor Browning's documents. 14MR JUSTICE GRAY: That is one I have not got here I am afraid. 15A.
[Mr Irving]
This is the actual conference. 16MR RAMPTON: At tab 11, no sorry. 17A.
[Mr Irving]
10. 18Q.
[Mr Rampton]
It is open at the right place but I just want to identify 19the document. 20MR JUSTICE GRAY: Tab 9, page 458. 21MR RAMPTON: It is called "Footnote 88" which is the Hans Frank 22extract which is printed in Professor Browning's report at 23paragraph 5.1.13 on pages 31 and 32. He has quoted some 24of that diary, but there is another passage here which 25I would like you to look at in the German, please, 26Mr Irving, while I read slowly a translation.

. P-182

1A.
[Mr Irving]
Presumably the second paragraph? 2Q.
[Mr Rampton]
The first complete paragraph on page 458. This is the 3Hans Frank so-called "diary". Correct me as soon as I go 4wrong. No, I will read it once and then when we go 5through it again you tell me how this translation is in 6error, if it is. 7 "For us the Jews are also particularly useless, 8might be damaging, consumers of food, mouths. We have 9approximately 2.5, perhaps with those related to Jews and 10all that belongs to that 3.5 million Jews. We can't shoot 11these 3.5 million Jews. We can't poison them. But we 12will, however, be able to undertake interventions which in 13some way lead to a successful annihilation, and indeed in 14connection with the large scale measures to be undertaken 15from the Reich and to be discussed. The General 16Government must become just as free of Jews as the Reich 17is. Where and how that happens is a matter for the 18institutions which we must put into action and create here 19and the effectiveness of which I will report on to you in 20good time." 21 Is that roughly an accurate translation of that 22paragraph? 23A.
[Mr Irving]
Just two minor beefs, as I would call them. I would say 24in connection with, where he says "in connection with the 25measures to be discussed from the Reich", I would say "in 26the context of" is probably a more apposite description.

. P-183

1When he talks about "the institutions", "is a matter for 2the institutions", "instansun(?)" would be more accurately 3translated as "departments" in the sense of government 4departments. 5Q.
[Mr Rampton]
Yes. I am happy to wear that correction for the moment. 6I do not know whether the translator is. I will find that 7out later. Does that not, Mr Irving, completely demolish 8the idea that in Berlin it was Frank who was telling the 9people in Berlin "liquidate the Jews yourselves"? Is he 10not here expanding on the instruction from Berlin, 11"liquidate them yourselves"? 12A.
[Mr Irving]
May I first of all make plain that I had not seen this 13passage at the time I wrote the book. So this is not 14something that lay before me when I wrote my books. Can 15I make that quite plain on oath? 16Q.
[Mr Rampton]
Yes. 17A.
[Mr Irving]
You will find this when I produce the materials that I had 18that were given to me by the Institute from the Hans Frank 19diaries. Secondly, it confirms what I said about them 20already having more Jews in the Government General than 21they could handle. They could not feed and house the ones 22they did have and they were very indignant at any more 23being dumped on them given the problems they had of 24feeding the mouths they already had. 25Q.
[Mr Rampton]
He is saying: "We have got two and a half, maybe three 26and a half million Jews in this part of the Reich occupied

. P-184

1territories, we cannot shoot them all, we cannot poison 2them." 3A.
[Mr Irving]
He says "we can't shoot them". He does not say "all". 4There is a subtle difference there. 5Q.
[Mr Rampton]
Is it? 6A.
[Mr Irving]
Yes. 7Q.
[Mr Rampton]
Oh. 8A.
[Mr Irving]
Yes, otherwise it implies they can shoot some. If I am 9saying I cannot shoot all the people in this room, that 10implies half the people in this room have a rather bleak 11lookout. 12MR JUSTICE GRAY: Yes, but making the place phrase "Judenfrage" 13is pretty unambiguous. 14A.
[Mr Irving]
No, the actual phrase that has been translated here, he 15says: "These 3.5 million, we can't shoot them. We can't 16poison them", and Mr Rampton just slid in the word "all". 17MR RAMPTON: Oh, no. I am paraphrasing. Be kind to me, 18Mr Irving. 19A.
[Mr Irving]
You put in the word "all". We all heard you say it. 20Q.
[Mr Rampton]
Of course it does, but that is what it means? 21A.
[Mr Irving]
No. What it means is quite plain. "We can't shoot them". 22Q.
[Mr Rampton]
How do you make the General Government "Judenfrage" if you 23do not get rid of all the Jews, if you do not achieve a 24vernichtung serfolg? 25A.
[Mr Irving]
I do not want to labour the point. If you say that we 26cannot shoot them all, that implies we can shoot some of

. P-185

1them. If he says we cannot shoot the Jews that implies we 2cannot shoot any of them. 3Q.
[Mr Rampton]
That will do. We cannot poison them. We cannot shoot 3.5 4million. We cannot poison 3.5 million? 5A.
[Mr Irving]
But we will be able to do something, he goes on to say, 6which will lead to wiping them out, getting rid of them, 7vernichtung. 8Q.
[Mr Rampton]
Getting rid of? 9A.
[Mr Irving]
Vernichtung. 10Q.
[Mr Rampton]
Vernichtung is to get rid of? 11A.
[Mr Irving]
I am just saying the sense of this sentence is, "we can't 12kill them, we can do something that will get rid of them." 13Q.
[Mr Rampton]
It is not. 14A.
[Mr Irving]
He just said, "We can't poison, we can't shoot them". 15Whatever ways would you suggest? 16Q.
[Mr Rampton]
Gas, Mr Irving, gas? 17A.
[Mr Irving]
Vergeltung? It sounds like poisoning to me, poison gas. 18Q.
[Mr Rampton]
"Gift gas" is poison gas. Vergeltung is poison? 19A.
[Mr Irving]
That is right, he says "we can't do it". 20Q.
[Mr Rampton]
Yes. He does not say anything about gassing. This is an 21evolutionary document. 22A.
[Mr Irving]
No point using gas if it is not poison gas. 23MR JUSTICE GRAY: Mr Irving, I am not sure I got your answer to 24the initial question which was, does this or does it not 25show that the instructions were from Berlin to the General 26Government as to what was to be done in the General

. P-186

1Government? 2A.
[Mr Irving]
I am sorry, my Lord, if I did not make myself plain. I 3thought that this in fact supported my version that Hans 4Frank was saying that they already had all the Jews they 5could handle. They could not even feed the ones they had 6got: "So please don't send us any more, get rid of them 7yourself". 8MR RAMPTON: So the word "vernichtung serfolg" is not talking 9about a liquidation? 10A.
[Mr Irving]
If you want to wipe out Christianity you do not have to 11liquidate the Christians. 12Q.
[Mr Rampton]
I do not see anything about Judaism in this passage. It 13is all about Jews, numbers of Jews, 3.5 million? 14A.
[Mr Irving]
He says here explicitly, "We can't kill", he says, I will 15translate it for you and it is exactly the same as your 16translation there. "These 3.5 million Jews, we can't 17shoot them, we can't poison them, but we will be able to 18do something which will one way or another lead to a 19successful wipe out, destruction". 20Q.
[Mr Rampton]
Annihilation? 21A.
[Mr Irving]
"We will get rid of them". We are back on that word 22vernichtung again, which Germans who like using these 23words in the knowledge they are going to be providing 24endless humour for lawyers 50 years down the road. 25Q.
[Mr Rampton]
I do not think it is very humorous, Mr Irving, I am bound 26to say, not humorous at all.

. P-187

1A.
[Mr Irving]
That is why I prefer to sit on documents where it is 2absolutely unambiguous where we do not have to waste time 3about the meanings of words. 4Q.
[Mr Rampton]
You mentioned I think, whether it was this morning or 5yesterday I am afraid I cannot remember, somebody called 6Wisliceny? 7A.
[Mr Irving]
Wisliceny, W-I-S-L-I-C-E-N-Y. 8Q.
[Mr Rampton]
Yes. He was I think on Eichmann's staff, was he not? 9A.
[Mr Irving]
A member of Eichmann's staff who was responsible for the 10Final Solution in Slovakia and other countries. 11Q.
[Mr Rampton]
He made some statements after the war, did he not? 12A.
[Mr Irving]
Under duress, yes. 13Q.
[Mr Rampton]
What do you mean by duress? 14A.
[Mr Irving]
In Allied captivity, inside the gallows, which is about as 15much duress as you can imagine. 16Q.
[Mr Rampton]
You are not saying he was tortured? 17A.
[Mr Irving]
Good Lord no. 18Q.
[Mr Rampton]
You say that Rudolf Hess was tortured, do you not? 19A.
[Mr Irving]
I say that he was maltreated. He had a torch rammed into 20his mouth. 21MR JUSTICE GRAY: Let us stick with Wisliceny for the moment 22otherwise we are going to get confused. 23MR RAMPTON: That is my fault, my Lord. 24A.
[Mr Irving]
He richly deserved it, people like that. 25Q.
[Mr Rampton]
No, I do not agree with that as it happens, Mr Irving. 26Can you see if you still have Professor Evans' report

. P-188

1there? It was handed to you in error earlier. 2A.
[Mr Irving]
Yes. 3Q.
[Mr Rampton]
I am sorry. Let us turn to page 344, will you? 4A.
[Mr Irving]
Yes. 5Q.
[Mr Rampton]
Evans' report. It is at letter G and Professor Evans 6writes this, Mr Irving. I will not read the heading 7except to say it says "Testimony of Dieter Wisliceny". 8A.
[Mr Irving]
It also says: "Manipulation and Suppression of Evidence". 9Q.
[Mr Rampton]
I was going to save your blushes. Yes, it does, does it 10not? 11A.
[Mr Irving]
Yes. 12Q.
[Mr Rampton]
"As described above, Irving claims that Dieter Wisliceny, 13one of Eichmann's top officials, described Goebbels' 14article in Das Reich as a watershed in the Final Solution 15of the Jewish problem. Once more Irving makes it very 16difficult to verify claims. According to his footnotes, 17Wisliceny's postwar report of 18th November 1946 can be 18found in the IFZ file F71/8. However, this file does not 19exist and Wisliceny's report has to be located elsewhere." 20 It is a minor point, Mr Irving. Do you accept 21that you gave a wrong reference? 22A.
[Mr Irving]
No. I saw this file probably 30 years ago, probably 23before Professor Longerich was born. 24Q.
[Mr Rampton]
This is not Professor Longerich. This is Professor 25Evans. 26A.
[Mr Irving]
Well, even more to the point. That being so, it is

. P-189

1extremely likely that they changed the reference number 2since the archives are constantly changing reference 3numbers. 4Q.
[Mr Rampton]
It is a small point. "In his report Wisliceny states that 5after the invasion of the USSR in June 1941 Nazi policy 6against the Jews was transformed dramatically in a 7step-by-step process, completed in the Spring of 1942. 8One these radicalisng steps was taken in late 1941. As 9Wisliceny reported: 'The second wave of radicalization 10began after the USA entered the war. This could clearly 11be felt in the internal German propaganda too. Externally 12it was expressed in the introduction of the yellow star as 13a mark of the Jews. Reference in this connection also to 14the Goebbels' article that 'Jews are guilty' in an edition 15of the magazine Das Reich'. 16 "In this period of time, after the beginning of 17the war with the USA, I am convinced must fall the 18decision of Hitler which ordered the biological 19annihilation of European Jewry" -- biologische vernichtung 20des europaischen Judentums befahl. 21A.
[Mr Irving]
Yes. 22Q.
[Mr Rampton]
You are well aware of that passage? 23A.
[Mr Irving]
Yes, and I draw attention to the fact that in order to 24emphasis that the word "vernichtung" here means killing he 25adds the adjective "biologische", biological, because 26without that it does not mean it with sufficient emphasis.

. P-190

1MR JUSTICE GRAY: Do not let us go back on that. 2MR RAMPTON: You can argue about it. Eventually, you see, 3Mr Irving, whatever you may think and whatever I may put 4to you, his Lordship will make a decision about what the 5natural meaning of the word is in these various contexts. 6A.
[Mr Irving]
But without input from me he will only hear input from 7you. 8Q.
[Mr Rampton]
Of course you must say what you think it means. Whether I 9or anybody else accepts what you say is quite another 10matter. 11A.
[Mr Irving]
But I think it is quite useful to say it here in view of 12the fact that this man obviously thought that 13"vernichtung" does not mean killing unless he adds the 14word "biologische" in front of it. 15MR JUSTICE GRAY: I do not think that is right actually, but 16I have the point. It is obvious what it means if it has 17"biological" attached to it. If it has not, you say it 18does not mean extermination. Mr Rampton says it does. 19I think we really have thrashed that one. 20MR RAMPTON: I am afraid I am going to take up, argumentative 21person that I am, one little point on this. You notice, 22do you not, that although you stress the use of the word 23"biologische" to qualify "vernichtung", what is it that 24is being biologically annihilated? 25A.
[Mr Irving]
Judentums. 26Q.
[Mr Rampton]
Judentums?

. P-191

1A.
[Mr Irving]
Yes. 2Q.
[Mr Rampton]
European Judentums? 3A.
[Mr Irving]
Yes. 4Q.
[Mr Rampton]
What is "Judentums"? 5A.
[Mr Irving]
In this case quite clearly he is talking about the Jews 6because he has added the word "biological in advance" and 7you cannot have biological in reference to provision. 8Q.
[Mr Rampton]
There is no rule of German which says that the word must 9mean Judaism. It can easily mean Jewish people or Jewry 10as a collective, can it not? 11A.
[Mr Irving]
I do not want to labour the point, but this is why 12dictionaries give orders of priority for the meanings of 13words, the first meaning, second meaning and third meaning 14and so on. 15Q.
[Mr Rampton]
Wisliceny thinks or says that he things, is reported as 16saying that he thinks, that the order for the biological 17annihilation of the European Jews came from Hitler. He is 18saying that, is he not? 19A.
[Mr Irving]
He could set that conviction of his to music and play it 20to the mass bands of the Cold Stream Guards, but it does 21not make it proof. 22Q.
[Mr Rampton]
He says it again and again. Is it right that you have 23consistently ignored what he said? 24A.
[Mr Irving]
What is the date of this report, Mr Rampton? 25Q.
[Mr Rampton]
It is 1946, 18th November 1946. 26A.
[Mr Irving]
Just two or three weeks after the unfortunate Nazi

. P-192

1gangsters have been hanged at Nuremberg. Where is he 2writing this report? 3Q.
[Mr Rampton]
Is the answer to my question, yes? Give the explanation 4afterwards, please, Mr Irving. The answer to my question 5is, yes, you have ignored it. Now the reason ---- 6A.
[Mr Irving]
No. The answer to the question is that I have discounted 7that kind of evidence as being the fact that he does not 8say he saw an order. He is saying it is his opinion. He 9thinks that, yes, there must surely have been some such 10kind of order. What kind of evidence is that given by a 11man sitting in the face of the gallows just after the Nazi 12leaders have been hanged at Nuremberg, and he is sitting 13in Czech Slovac prison knowing that he is going to be 14hanged as well, and he is sitting down there writing the 15first thing that comes into his head, and he says: "Well, 16surely Hitler must have given an order." What kind of 17evidence is that? What kind of historian would I be who 18in the absence of any kind of documentation whatsoever of 19any concrete diamond value of the war archives then 20decides to pollute his work with relying on this kind of 21documentation? Material that Wisliceny himself is an 22expert on -- I remind you of the Trevor Roper criteria, 23something that he himself has experienced, something that 24he is in a position to know. That I would accept, but for 25him to speculate, as he clearly is here, that is neither 26here nor there. It is information of janitorial level.

. P-193

1Q.
[Mr Rampton]
Yes. Janitorial, this is to anticipate something we are 2going to come to perhaps next week or the week after, Mr 3Irving, but "janitorial level" is a phrase you often use. 4Is not "janitorial level" very often the place you expect 5to find the diamonds? 6A.
[Mr Irving]
Janitorial level is not the kind of place that 7I frequently inhabit, Mr Rampton. 8Q.
[Mr Rampton]
That is very patrician of you, Mr Irving. If you are an 9historian you must look even in the basement, the sewer, 10if you want to find the gems, must you not sometimes? 11A.
[Mr Irving]
If one fails to find the gems, my opponents and my jealous 12rivals they have gone down among the sewers looking for 13things, but I found the gems because I have done the work. 14Q.
[Mr Rampton]
You saw some of them, did you not, in Professor van Pelt's 15report, "janitorial gems"? 16A.
[Mr Irving]
We shall have great enjoyment discussing this with van 17Pelt when the time comes. 18MR JUSTICE GRAY: Can I just understand why Wisliceny is being 19put into the janitorial category at all? He is one of 20Eichmann's top officials. 21A.
[Mr Irving]
He is one of Eichmann's top officials. 22Q.
[Mr Justice Gray]
And Eichmann was one of the senior officials within the 23Reich carrying out the extermination programme. 24A.
[Mr Irving]
Mr Wisliceny is a man who is in deep trouble. First of 25all he is facing ---- 26Q.
[Mr Justice Gray]
That is a different point, if I may say so. He is not a

. P-194

1janitor. 2A.
[Mr Irving]
He is also a man of very dubious character. He is a man 3who has been not an officer in the SS, but he has been 4involved in corrupt schemes, in stealing and robbing and 5disposing of stolen Jewish property and all sorts of 6things that got him in trouble even with the SS. He is a 7man whose character I would not give a fig for. He is 8sitting in a prison cell in a Slovac prison knowing that 9he is going to be put on trial for his life. 10Q.
[Mr Justice Gray]
That is a different point. 11A.
[Mr Irving]
I am sorry, let me cut to the bottom line and say what he 12is actually saying here, I have lost it, he is not saying 13"I know this for a fact"; he is just saying, "I speculate 14that probably this happened." I have lost it totally, the 15actual reference. 16Q.
[Mr Justice Gray]
"I am convinced it must fall the decision of Hitler". 17A.
[Mr Irving]
Yes, but his conviction that something must fall within, I 18mean, that is not evidence of any kind at all, my Lord, 19and I am sure no court would accept that kind of evidence 20in a matter of great seriousness, somebody's conviction 21that something must surely have happened, not in the total 22absence of any kind of qualifying documents. 23MR RAMPTON: I am sorry, Mr Irving. Sometimes my questions 24involve quite a lot of paper chasing. You are quite 25content to use Dieter Wisliceny when it suits your 26purposes, are you not?

. P-195

1A.
[Mr Irving]
If it fits the criteria which I mentioned earlier. 2Q.
[Mr Rampton]
If it fits the bill, I would suggest, Mr Irving. 3A.
[Mr Irving]
That is not what I said. I said if it fits the criteriA. 4Q.
[Mr Rampton]
Have you got your Goebbels' book there? 5A.
[Mr Irving]
Yes. 6Q.
[Mr Rampton]
You say on page 379 -- has your Lordship got one? 7MR JUSTICE GRAY: Yes, I have. 379, you say? 8MR RAMPTON: Yes. 9A.
[Mr Irving]
Yes, I have that. 10Q.
[Mr Rampton]
We are talking here about an article written by, or 11probably written by, Dr Goebbels? 12A.
[Mr Irving]
It is one of the two most important articles he wrote. 13Q.
[Mr Rampton]
You say that; it was written and published, I think, on 1416th December? 15A.
[Mr Irving]
November. 16Q.
[Mr Rampton]
I am sorry, November? 17A.
[Mr Irving]
1941. 18Q.
[Mr Rampton]
1941, as virulently anti-Semitic as anything that Hitler 19ever said? 20A.
[Mr Irving]
Far more so. 21Q.
[Mr Rampton]
You say that, do you? 22A.
[Mr Irving]
Far more so. 23Q.
[Mr Rampton]
You say here on page 379 in the last paragraph, the 24complete paragraph, on the page: "Dieter Wisliceny, one 25of Eichmann's closest associates, would describe the 26Goebbels' article in Das Reiche", that is the one I

. P-196

1have just mentioned, as a watershed in the Final Solution 2of the Jewish problem". Then footnote 40 is a reference 3to the Wisliceny Report, date November 18th 1946. That is 4to be found on page 645. You go on in the text ---- 5A.
[Mr Irving]
I also reference his interrogations I see. 6Q.
[Mr Rampton]
You did. 7A.
[Mr Irving]
Yes. 8Q.
[Mr Rampton]
"The SS took it as a sign from above Adolf Eichmann would 9admit in his unpublished memoirs it is quite possible that 10I got orders to direct this or that railroad to Riga", and 11I don't know where we go from there quite. Yes, I will 12read the whole paragraph. "On the last day of November, 13on the orders of the local SS Commander, Friedrich 14Jeckelm, 4,000 of Riga's unwanted Jews were trucked five 15miles down" -- the Germans called that Dinoberg, I think, 16did they not? 17A.
[Mr Irving]
Dunoberg, yes. 18Q.
[Mr Rampton]
-- "a highway to Skiaturbe plundered and machine-gunned 19into two or three pits. According to one army colonel", 20this is Bruns, is it not---- 22Q.
[Mr Rampton]
--- who witnessed it, a trainload of Jews from Berlin, 23those expelled three days before, arrived in the midst 24of this aktion. Its passengers were taken straight out to 25the pits and shot. This happened", and here we go again, 26even has Hitler's hundreds of miles away, "Hitler", I

. P-197

1emphasise, hundreds of miles away in the Wolf's Lair, "was 2instructing Himmler that these Berlin Jews were not to be 3liquidated. I am not going back to that hoary old 4chestnut, you will be glad to hear, but I do want to take 5you back to the beginning of this paragraph. 6A.
[Mr Irving]
It is a remarkable paragraph for a Holocaust denier to 7write, is it not? 8Q.
[Mr Rampton]
I have no idea, Mr Irving, and anyway I am not going to 9answer your question. "Dieter Wisliceny, one 10of Eichmann's closest associates, would describe the 11Goebbels' article in Das Reich as a watershed in the Final 12Solution of the Jewish problem"? 13A.
[Mr Irving]
Yes. 14Q.
[Mr Rampton]
Where did he give that description? 15A.
[Mr Irving]
What, whether he actually used the word watershed? 16Q.
[Mr Rampton]
Yes. 17A.
[Mr Irving]
You see that I reference his manuscript written in 18Bratislava or Presburg and I also reference the 19interrogations in the associated footnote. 20Q.
[Mr Rampton]
But if you read what we find here in Professor Evans' 21report which is an English translation of some part of the 22Wisliceny report, what you immediately realize, you do not 23learn it from Mr Irving's books, you learn it 24from Professor Evans' report, what you immediately realize 25is that Dieter Wisliceny did not see the Reich article as 26a watershed. He saw the watershed as being an order from

. P-198

1Adolf Hitler? 2A.
[Mr Irving]
Can we have a look at the passage you are relying on, 3please? 4Q.
[Mr Rampton]
The which? 5A.
[Mr Irving]
The passage of the Wisliceny report you are relying upon 6in the Evans... 7Q.
[Mr Rampton]
One would have to go back now to ---- 8A.
[Mr Irving]
I no longer trust your paraphrases, you see, Mr Rampton. 9Q.
[Mr Rampton]
--- where I was. 10MR JUSTICE GRAY: It is page 340, I think. 11MR RAMPTON: Yes. 345, sorry, my Lord. The passage -- I am 12not going to read it again, I have read it once already. 13Read what is said there. The German is at the bottom of 14the page, so if you are going to criticise Professor 15Evans' translation, say so now. 16A.
[Mr Irving]
The English is a slightly vague translation. I am looking 17at the paragraph at the top of page 345, where he says 18this is just simply "reference in this connection also to 19the Goebbels-article" ---- 20Q.
[Mr Rampton]
Yes? 21A.
[Mr Irving]
--- "'The Jews are guilty'". 22Q.
[Mr Rampton]
What does the German say? 23A.
[Mr Irving]
The German says: "In this connection, I draw attention 24also to the Goebbels-article 'The Jews are to blame' in an 25edition of the newspaper Das Reich" which is possibly a 26slightly more coherent way of translating it.

. P-199

1Q.
[Mr Rampton]
But he is talking about German propaganda, that is to say, 2domestic propaganda, is he not? 3A.
[Mr Irving]
Yes. 4Q.
[Mr Rampton]
After 11th December when Hitler, perhaps rather stupidly, 5declared war on the United States? 6A.
[Mr Irving]
Yes. 7Q.
[Mr Rampton]
He is talking about the Yellow Star and he is talking 8about the article in Das Reich as examples. He then 9said: "In this period of time, after the beginning of the 10war with the USA, I am convinced must fall the decision of 11Hitler which ordered the biological annihilation of 12European Jews". So how is it, if that is the piece you 13were referring to, that that gets converted into Dieter 14Wisliceny saying that the article by Goebbels in Das Reich 15was a watershed? 16A.
[Mr Irving]
I beg to differ with you. I think that even this source 17bears me out. He said the words you omitted in your 18summary, he says: "The second wave of radicalization 19began" and the instance of this he gives is the 20publication of the article. This is what triggered off 21the off the second wave of radicalization. But you have 22also overlooked, and I am sorry I tripped you up on this 23when you referred to the Goebbels' Diaries, would you like 24to read out the reference for the passage that I gave 25you? You implied that it relies only on the Wisliceny 26report.

. P-200

1Q.
[Mr Rampton]
No, you refer to something else, but so what? Sorry, I am 2not following you. 3A.
[Mr Irving]
If you look in the source reference, it clearly says: 4"Wisliceny report and interrogations of Wisliceny in the 5national archives" which Professor Evans has obviously not 6bothered to look at. 7Q.
[Mr Rampton]
I am quite open-minded, Mr Irving. If you tell me that in 8the interrogations, as opposed to the report, there is a 9positive statement by Wisliceny to the effect that 10Goebbels' article was the watershed or a watershed, then 11I will accept it, if you tell me to find it? 12A.
[Mr Irving]
Mr Rampton, I am under oath and I am not going to make a 13statement from memory for something that I cannot back up 14without going home and checking the files. All that I do 15say is that Professor Evans has made no reference to the 16fact that I used other sources to justify that one 17sentence and that he, apparently, has not bothered to go 18and have a look at those interrogations of Wisliceny 19because they are so many thousands of miles away. 20Q.
[Mr Rampton]
We may just have time to go over to the other side of this 21page in Evans' Report, 346 at paragraph 4. This is a 22further extract, says Professor Evans -- of course, you 23may prove that he is wrong about it -- this is an extract 24from the same document, apparently, where Wisliceny says 25this: 26 "According to Eichmann's own report, which he

. P-201

1made to me, Globocnig (sic) was the first to use gas 2chambers for the mass extermination of humans. Globocnig 3had set up big labour camps for Jews in his area of 4command, and he got rid of those who were unable to work 5in the manner described. As Eichmann explained, 6this 'procedure' was 'less conspicuous' than the mass 7shootings". The German is "Massenerschiessungen". Do you 8remember those words? Do they ring a bell? 9A.
[Mr Irving]
Yes, indeed. 10Q.
[Mr Rampton]
Something to do with General Bruns? Does that ring a 11bell? 12A.
[Mr Irving]
Well, there were mass shootings occurring all over the 13Eastern Front. It is not specifically a reference just to 14that one. There were mass shootings at Riga, there were 15mass shootings at Minsk, mass shootings elsewhere in the 16Ukraine. So it would be specious just to say this is a 17reference to the Bruns Report. 18Q.
[Mr Rampton]
My point is a slightly different one. Indeed, it is not a 19reference to the Bruns Report. 20A.
[Mr Irving]
Well, you mentioned the Bruns. 21Q.
[Mr Rampton]
Exactly, and I will tell you why. What Bruns said he was 22told by Altemeyer was to precisely the same effect, "These 23mass shootings, or mass shootings of this kind, mass 24shootings, must stop. That must be done more discreetly"? 25A.
[Mr Irving]
Yes. 26Q.
[Mr Rampton]
It is almost a mirror image of what Wisliceny reports

. P-202

1Eichmann having said, this procedure, gassing, was less 2conspicuous, "unauffalliger" ---- 3A.
[Mr Irving]
Yes. 4Q.
[Mr Rampton]
--- than the "Massenerschiessungen"? 5A.
[Mr Irving]
This was the tendency in the SS; they did not like 6shooting people. Shooting took it out of them. 7Q.
[Mr Rampton]
Sure. 8A.
[Mr Irving]
Yes. 9Q.
[Mr Rampton]
And that is why they took to gassing people, is it not? 10MR JUSTICE GRAY: But you accept, do you, Mr Irving, that ---- 11A.
[Mr Irving]
Gassing did occur, yes. 12Q.
[Mr Justice Gray]
--- the Bruns Report corresponds with what is, apparently, 13recorded in Eichmann's report? 14MR RAMPTON: In Wisliceny's report, my Lord. 15MR JUSTICE GRAY: Sorry, in Wisliceny's report. 16MR RAMPTON: It is double hearsay, if you like, but so what if 17you are an historian. 18A.
[Mr Irving]
It is indeed and the word "report", of course, is slightly 19sharpening it up. He is actually just saying, "According 20to what Eichmann said", he is saying. 21MR RAMPTON: Do they not echo one another? 22A.
[Mr Irving]
Yes. 23Q.
[Mr Rampton]
Bruns is talking about shootings in the Osland in Latvia? 24A.
[Mr Irving]
Yes. 25Q.
[Mr Rampton]
Here Wisliceny is talking much more generally, is he not? 26A.
[Mr Irving]
Indeed, yes, and we do not know about what period he is

. P-203

1talking about, we do not know about what region he is 2talking about. 3Q.
[Mr Rampton]
Do you not detect in the convergence of those two 4completely otherwise unrelated pieces of evidence ---- 5A.
[Mr Irving]
Yes. 6Q.
[Mr Rampton]
--- even a hint of a suggestion that the reality was that 7mass shootings were embarrassing because they could get 8out because it upset the soldiers too much, because it was 9expensive in bullets, a shift in policy from shooting to a 10more discreet means of disposal, that is to say, gassing? 11A.
[Mr Irving]
I am afraid that was such a long question that I had lost 12you halfway through again. 13MR JUSTICE GRAY: Well, I think it is the end of a longish day 14for Mr Irving and I think we will... 15MR RAMPTON: I will repeat the question first thing on Monday 16morning. 17MR JUSTICE GRAY: Will you? 18MR RAMPTON: It will be on the transcript. 19A.
[Mr Irving]
Can you put it in two halves so that ---- 20MR JUSTICE GRAY: It was a long question. Anyway, we are 21adjourning now. 22A.
[Mr Irving]
--- a bear of limited brain can follow it, but I lost it. 23MR JUSTICE GRAY: So it is 10.30 on Monday in court 73. 24(The court adjourned until 10.30 p.m. on Monday, 17th25January 2000)26